- 12 - thereby, in 1984 (to the extent she was liable at all on the indebtedness to Northern Trust Co.), arguably realized discharge of indebtedness income taxable to her under section 61(a)(12). No such income was reported by petitioners on their 1984 joint Federal income tax return (nor charged to petitioners on audit by respondent), and such additional income would likely offset any portion of the claimed $1,064,164 net operating loss carryover if any such carryover were established in this case and if Eva were otherwise entitled thereto. Eva, however, has not established the existence of the claimed carryovers or that any portion of the claimed carryovers should be attributable to her. In the alternative and in a characteristically vague and unclear manner, petitioners apparently claim that they were not actually indebted to Northern Trust Co. If that is so, in now calculating the very large net operating loss carryover from 1984 to which petitioners claim to be entitled, petitioners would be required to recalculate the very large interest deductions (cumulatively in excess of $4.5 million) that they claimed in 1984 and prior years with respect to the purported indebtedness to Northern Trust Co. As a result, the claimed net operating loss carryover from 1984 (that is based largely on such claimed interest deductions) would be eliminated or substantiallyPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011