- 3 - during 1986 with bases in excess of $22,102 to which the parties stipulated? We hold that they did not. (5) Are petitioners entitled to a general business credit carryforward from 1986? We hold that they are not. FINDINGS OF FACT2 Some of the facts have been stipulated and are so found. Petitioners resided in Tucson, Arizona, at the time the petition was filed. Petitioners, who emigrated to the United States from Greece, have three children, all of whom they claimed as dependents in the returns that they filed for the years at issue. Petitioners' Restaurant Business--New Dolce Vita In General Petitioners have been involved in the restaurant business in the United States since 1977. In December 1985, petitioners executed a lease for property located at 6781 North Thornydale in Tucson, Arizona, at which they planned to operate a restaurant called New Dolce Vita (NDV) that was to specialize in Italian, American, and Greek cuisine. Petitioners provided all the fixtures and equipment for the restaurant, some of which they 2 Petitioners' opening brief did not contain all of the findings of fact that petitioners wanted to propose and that they were required to set forth in that brief, as required by Rule 151(e)(3). Instead, in violation of that Rule, their answering brief contained additional proposed findings of fact that the Court did not find to be "alternative proposed findings of facts" as permitted by Rule 151(e)(3).Page: Previous 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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