- 11 - Petitioners herein have made no attempt to establish the amount, if any, of the above-claimed carryovers that were recognized and used by the bankruptcy estate in Daniel's bankruptcy proceedings, and petitioners have not established the amount of any such carryovers to which Daniel succeeded at the termination of the bankruptcy. Also, respondent, in the alternative, disputes Eva's entitlement to any portion of the claimed $1,064,164 net operating loss and $38,839 investment credit carryovers. Eva apparently did not file for bankruptcy, but even if petitioners established that some of the claimed net operating loss and investment credit carryovers were attributable to Eva,2 Eva has not established the amount of any portion of the claimed net operating loss and investment credit carryovers to which she would be entitled. Further, in 1984, Eva apparently received a discharge with respect to whatever liability she had on a $16.8 million indebtedness to Northern Trust Co. Eva's discharge with respect to this liability occurred as part of a 1984 settlement of a lawsuit petitioners had filed against Northern Trust Co. Eva 2 We note that net profits were reported on the Schedules C relating to each of Eva's separate businesses that were attached to petitioners’ joint Federal income tax returns for 1984 and earlier years that are in evidence. Thus, no portion of the claimed carryovers appears to belong to Eva.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011