Zahirudeen Premji and Carol M. Premji - Page 2

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          Petitioners         Docket No.          Year           Deficiency           
          Zahirudeen and                                                              
          Carol M. Premji     8372-94             1990           $ 18,501             
          Carl John Norby     10353-94            1990           $ 15,959             
          In an Amendment to Answer filed in docket No. 8372-94 respondent            
          asserted an increased deficiency of $4,448 based on the                     
          allegation that petitioners Premji failed to report interest                
          income of $29,329 actually or constructively received in 1990.              
          Petitioners and respondent have made concessions with respect to            
          the amount of the interest income received by the Premjis, and              
          those concessions should be reflected in the computations for               
          entry of the decision.                                                      
               The primary issue in both of these cases is whether                    
          petitioners Premji and Norby are entitled to theft loss                     
          deductions in 1990 resulting from their investment of funds with            
          M&L Business Machine Company, Inc., which, through its officers             
          and shareholders, operated a ponzi scheme.  The resolution of               
          this issue depends on whether there existed a reasonable prospect           
          of recovery in that year.                                                   
               Secondary issues in the Premji case are whether petitioners            
          constructively received certain amounts of interest income in               
          1990 and whether certain amounts of interest actually received in           
          1990 constitute taxable income to them in that year.                        








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