Swallows Holding, Ltd. - Page 21

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          treated the subject returns as such an election, petitioner’s               
          income from the U.S. real estate for the subject years is treated           
          as effectively connected income.                                            
               On its Form 1120-F for its 1993 taxable year, petitioner               
          recognized option income of $16,290 and deducted an expense for             
          taxes of $52,081, resulting in a reported taxable loss of                   
          $35,791.  On the respective subject returns, petitioner                     
          recognized rental income of $12,000, $18,000, and $12,000 and               
          option income of $36,000, $21,000, and zero dollars.  Petitioner            
          also on the respective subject returns deducted expenses for                
          taxes and licenses in the total amounts of $77,059, $62,418, and            
          $40,041, resulting in reported losses (without consideration of             
          any net operating loss (NOL) carryforward) of $29,059, $23,418,             
          and $28,041.  Petitioner reported on its Form 1120-F for its 1994           
          taxable year that it had available as an NOL carryover its prior            
          year’s loss of $35,791.  Petitioner reported on its Form 1120-F             
          for its 1995 taxable year that it had available as an NOL                   
          carryover its prior years’ losses totaling $64,850 ($29,059 +               
          $35,791).  Petitioner reported on its Form 1120-F for its 1996              
          taxable year that it had available as an NOL carryover its prior            
          years’ losses totaling $88,268 ($23,418 + $29,059 + $35,791).               











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