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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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