- 14 -
Vannucci faxed the article to petitioner's attorney, Carol P.
Schaner. Thereafter, Ms. Schaner attempted to obtain compensation
for petitioner from this worldwide "victims fund". Ms. Schaner
received no response to her correspondence.
7. Petitioner's Federal Income Tax Returns
Petitioner did not initially report the interest income earned
by any of her Isle of Man accounts on her Federal income tax
returns.5 In October 1991, petitioner's accountant prepared
amended returns for petitioner's 1985-90 tax years to report
interest income from her Isle of Man accounts. These amended
returns were mailed to the Internal Revenue Service on November 26,
1991.
Petitioner deducted $185,493.79 as a loss arising from an
insolvent financial institution pursuant to section 165(l) on her
1991 Federal income tax return. Petitioner claimed this loss as a
result of the seizure of her account No. 03000571 at IOMB of BCCI,
S.A. As a result of this deduction, petitioner filed second
amended returns for 1988 and 1989, claiming net operating loss
carrybacks of $143,209 and $4,455, respectively.
5 Her original 1989 return, for example, neither
discloses the existence of the Isle of Man accounts nor reports
any interest income.
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