Wang
Wang v. Commissioner
Opinion
Lead Opinion
MEMORANDUM **
Stephen Wang appeals pro se from the tax court’s decision affirming the Commissioner of Internal Revenue’s determination of federal income tax due for 1987 based on Wang’s failure to report income derived from payoffs Wang received for illegally furnishing insider-trading information. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). We review de novo the tax court’s conclusions of law, and review for clear error its findings of fact. Baizer v. Comm’r, 204 F.3d 1231, 1233-34 (9th Cir. 2000). We affirm.
The tax court did not err in finding the Commissioner’s notice of deficiency timely. See 26 U.S.C. § 6501 (c)(1); Ballard v. Comm’r, 740 F.2d 659, 662 (8th Cir.1994).
The tax court properly concluded that Wang was not entitled to reduce his 1987 taxable income by claiming net operating loss carrybacks from 1988 and 1989. See King v. United States, 152 F.3d 1200, 1201 (9th Cir.1998) (holding that taxpayer is not allowed deduction for loss “incurred in trade or business” due to voluntary forfeiture of revenue from illegal activity).
Wang’s contention that he should be entitled to take advantage of the computational tax benefits of 26 U.S.C. § 1341 for the tax…