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Petitioner's bankruptcy estate was closed on December 2,
1993.
For each of the years 1976 through 1993, the trustee
apparently filed Federal income tax returns on behalf of
petitioner's bankruptcy estate. The trustee apparently claimed
on those returns for 1976 through 1980 carryforward deductions
relating to the $1,517,999 1975-NOL. The record in this case,
however, does not reflect any of those returns and does not
reflect the deductions or amounts thereof carried forward and
claimed on the Federal income tax returns filed by the trustee on
behalf of petitioner's bankruptcy estate.
For 1975 and 1977, the record does not indicate what
individual Federal income tax returns were filed by petitioners.
For 1976, petitioners apparently did not file an individual
Federal income tax return. For 1978 through 1981, petitioners
filed joint Federal income tax returns on which they did not
claim any portion of the $1,517,999 1975-NOL as a carryforward
deduction.
In 1982, however, petitioners filed amended joint Federal
income tax returns for 1978 through 1981 on each of which they
did claim the 1975-NOL as a carryforward deduction. For 1982
through 1991, petitioners filed timely joint Federal income tax
returns on each of which they also claimed the 1975-NOL as a
carryforward deduction.
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