- 2 - 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.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