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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.
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