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The 1980 through 1982 deficiencies are attributable solely to
respondent's determination that no investment tax or business
energy credits are allowable for the 1983 year, and hence, none
are available to carry back to 1980 through 1982. The issues
remaining for our consideration are: (1) Whether petitioners are
entitled to deduct various expenses paid by checks drawn on the
account of petitioner's S corporation; (2) whether $90,000 of
income received by petitioner in 1982 was repaid to a related
corporation during 1983, and if any amount was repaid, whether it
results in a deduction for petitioners; (3) whether petitioners
are liable for additions to tax for fraud under section 6653(b);1
and (4) whether the periods for assessment of income taxes had
expired before the notice of deficiency was issued.
FINDINGS OF FACT2
Petitioners resided in St. Petersburg, Florida, at the time
their petition was filed.3 Petitioners filed joint Federal
income tax returns and amended returns on the following dates:
Year Original Filed Amended Filed
1980 Mar. 25, 1983 Dec. 4, 1985
1981 Mar. 25, 1983 Dec. 4, 1985
1982 Mar. 10, 1984 Dec. 4, 1985
1983 June 23, 1984 Dec. 4, 1985
1 Section references are to the Internal Revenue Code in
effect for the taxable years under consideration. Rule
references are to this Court's Rules of Practice and Procedure.
2 The parties' stipulation of facts and the attached
exhibits are incorporated by this reference.
3 Jack R. Prewitt maintained his residence in St.
Petersburg, Florida, but at the time the petition was filed, he
was incarcerated in the Federal Prison Camp located on Tyndall
Air Force Base, which is situated in the State of Florida.
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