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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1989 $28,242 $5,648
1990 24,401 4,880
1991 4,624 ---
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After settlement of some issues, the primary issue for
decision is whether a net operating loss from 1975 (1975-NOL) can
be carried forward to 1989, 1990, and 1991.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner Joyce E. Beery
resided in Los Alamos, New Mexico, and petitioner Jerome G. Beery
(petitioner) resided in Placitis, New Mexico.
During 1975, petitioner owned and managed in Colby, Kansas,
two businesses as sole proprietorships -- a farm and a grain
distributorship. Also during 1975, petitioner owned and managed
in Colby, Kansas, a branch of Mayer-Gelbort-Leslie, Inc., a
commodities trading firm based in Chicago, and petitioner made
investments in commodities.
In his combined businesses, in 1975, petitioner incurred
total net operating losses of $1,517,999 (1975-NOL).
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