MERLO v. COMMISSIONER

Docket No. 21538-03.

126 T.C. 205 (2006)

126 T.C. No. 10

ROBERT J. MERLO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 25, 2006.


Attorney(s) appearing for the Case

Don Paul Badgley, Brian G. Isaacson, and Duncan C. Turner, for petitioner.

Julie L. Payne and Kirk M. Paxson, for respondent.


OPINION

HAINES, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes of $4,833 and $169,510 for the years 1999 and 2000, respectively. After concessions,1 the issues for decision are: (1) Whether the capital loss limitations of sections 1211 and 1212 apply to the calculation of alternative minimum taxable income (AMTI); and (2) whether petitioner may...

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