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thereby, in 1984 (to the extent she was liable at all on the
indebtedness to Northern Trust Co.), arguably realized discharge
of indebtedness income taxable to her under section 61(a)(12).
No such income was reported by petitioners on their 1984 joint
Federal income tax return (nor charged to petitioners on audit by
respondent), and such additional income would likely offset any
portion of the claimed $1,064,164 net operating loss carryover if
any such carryover were established in this case and if Eva were
otherwise entitled thereto.
Eva, however, has not established the existence of the
claimed carryovers or that any portion of the claimed carryovers
should be attributable to her.
In the alternative and in a characteristically vague and
unclear manner, petitioners apparently claim that they were not
actually indebted to Northern Trust Co. If that is so, in now
calculating the very large net operating loss carryover from 1984
to which petitioners claim to be entitled, petitioners would be
required to recalculate the very large interest deductions
(cumulatively in excess of $4.5 million) that they claimed in
1984 and prior years with respect to the purported indebtedness
to Northern Trust Co. As a result, the claimed net operating
loss carryover from 1984 (that is based largely on such claimed
interest deductions) would be eliminated or substantially
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