Daniel R. Leavell and Eva Lovene Leavell - Page 11

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            Petitioners herein have made no attempt to establish the amount,                              
            if any, of the above-claimed carryovers that were recognized and                              
            used by the bankruptcy estate in Daniel's bankruptcy proceedings,                             
            and petitioners have not established the amount of any such                                   
            carryovers to which Daniel succeeded at the termination of the                                
            bankruptcy.                                                                                   
                 Also, respondent, in the alternative, disputes Eva's                                     
            entitlement to any portion of the claimed $1,064,164 net                                      
            operating loss and $38,839 investment credit carryovers.  Eva                                 
            apparently did not file for bankruptcy, but even if petitioners                               
            established that some of the claimed net operating loss and                                   
            investment credit carryovers were attributable to Eva,2 Eva has                               
            not established the amount of any portion of the claimed net                                  
            operating loss and investment credit carryovers to which she                                  
            would be entitled.                                                                            
                 Further, in 1984, Eva apparently received a discharge with                               
            respect to whatever liability she had on a $16.8 million                                      
            indebtedness to Northern Trust Co.  Eva's discharge with respect                              
            to this liability occurred as part of a 1984 settlement of a                                  
            lawsuit petitioners had filed against Northern Trust Co.  Eva                                 


            2     We note that net profits were reported on the Schedules C                               
            relating to each of Eva's separate businesses that were attached                              
            to petitioners’ joint Federal income tax returns for 1984 and                                 
            earlier years that are in evidence.  Thus, no portion of the                                  
            claimed carryovers appears to belong to Eva.                                                  






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