- 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).
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