T.C. Memo. 1995-497
UNITED STATES TAX COURT
ANDREW ZARDS AND MARGITA ZARDS, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 20388-91, 20389-91, Filed October 16, 1995.
20390-91, 2277-93.
GS is an S corporation, and Ps' claimed losses
passed through from GS. R disallowed Ps' losses on
various grounds including Ps' failure to (1) establish
that the losses were incurred in a trade or business
for the production of income and (2) substantiate that
the expenses giving rise to the losses actually were
incurred or paid.
Held: R's disallowance is sustained. Ps failed
to prove that GS was carrying on a trade or business
during the years in issue and that GS ever incurred or
paid its claimed expenses.
Victoria M. Brown, for petitioners.
Diane R. Mirabito, for respondent.
1 Cases of the following petitioners are consolidated
herewith: Janet Weinman, docket No. 20389-91; Vincent Donahue,
docket No. 20390-91; and Valdis and Vaida Vipulis, docket No.
2277-93.
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