Joyce E. and Jerome G. Beery - Page 6

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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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