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GNYP v. COMMISSIONER

Docket No. 39928-86.

56 T.C.M. 451 (1988)

T.C. Memo. 1988-488

Richard A. and Barbara F. Gnyp v. Commissioner.

United States Tax Court.

Filed October 6, 1988.

Attorney(s) appearing for the Case

Richard A. Gnyp, pro se. Andrew J. Mandell, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $3,034.00 in petitioners' Federal income tax for the taxable year ended December 31, 1981 and an addition to tax of $22.00 under section 6651(a)(1).1 The sole issue is the availability to petitioners of a net operating loss carryover from the taxable year ended December 31, 1974.

This case was submitted fully stipulated. The facts as set forth...

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