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by lending institutions to the interest expense incurred on the
outstanding loans to petitioner and his spouse, and (2)
additional payments were applied by the lending institutions to
the interest expenses incurred on the outstanding loans in the
total amounts of $11,987.85 for 1987 and $3,774.01 for 1988.
On their joint Federal income tax returns for 1986, 1987,
and 1988, petitioner and his spouse did not claim interest
expense deductions in the amounts of $147,624.52, $11,987.85, and
$3,774.01, respectively. Additionally, petitioner and his spouse
did not make any such claim as a part of their petition filed in
this case.
Subsequent to the issuance of the notice of deficiency and
the filing of the petition in this case, petitioner
substantiated, and respondent's counsel conditionally conceded,
that petitioner is entitled to net operating loss carryforwards
into the years 1986, 1987, and 1988 in the amounts of $64,196,
$12,736, and $13,786, respectively. Petitioner and his spouse
did not claim any net operating loss deduction on their joint
Federal income tax returns for 1986, 1987, and 1988.
Additionally, petitioner and his spouse did not make any such
claims as part of their petition in this case.
On their joint Federal income tax returns for 1986, 1987,
and 1988, petitioner and his spouse reported receipt of pension
income. Petitioner and his spouse attached to their Federal
income tax returns for 1986, 1987, and 1988 Forms W-2p, Statement
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