- 4 -
Byrne's wife died on July 28, 1988, Frances E. Byrne Jr.
(Frances) and Kimberly Byrne, Byrne's daughters, became NII's
sole shareholders.
Byrne has been a director of NII during most of its
existence, including the years in issue. He was also its
president from 1971 until he resigned on October 9, 1982, and its
vice president during the years in issue. After resigning as
president of NII, his daughter, Frances, succeeded him. His wife
was secretary of the corporation until her death. During 1989
and 1990, NII paid no employee compensation.
Respondent's notice of deficiency denies all of petitioner's
deductions for 1989 and 1990. Part of petitioner's net operating
loss carryover deductions come from depreciation, interest, and
other deductions incurred in prior years and in part from the
losses of petitioner's subsidiaries incurred in those years.
Establishing the net operating loss, therefore, requires
substantiating the deductions incurred by petitioner's
subsidiaries from as far back as 1975 and demonstrating their
business purpose. Establishing the amount of depreciation on a
building owned by petitioner requires substantiating its original
unadjusted basis in 1971. Interest deductions claimed by
petitioner relate to five different notes secured by petitioner's
building from time to time since 1971.
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