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SPITZ v. COMMISSIONER

Docket No. 4075-05.

92 T.C.M. 121 (2006)

T.C. Memo. 2006-168

Mark Spitz, v. Commissioner.

United States Tax Court.

August 15, 2006.

Attorney(s) appearing for the Case

Don Paul Badgley and Brian Gary Isaacson, for petitioner.

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

MEMORANDUM OPINION

HAINES, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes of $183,743 and $76,227 as well as additions to tax under section 6662 of $36,749 and $15,245 for 2000 and 2001 (years at issue), respectively.1

After concessions,2 the issues for decision are: 1) Whether the capital loss limitations of section 1211 apply to the computation of alternative...

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