2 After concessions, the issues for decision are: (1) Whether petitioners had enough of a basis in Bob Wade Ford, Inc. (Bob Wade Ford), to deduct losses of $256,752 in 1988 and $133,709 in 1989, as petitioners contend; had a zero basis, as respondent contends; or had a basis of some other amount; and, if petitioners establish that they had enough of a basis to deduct losses, whether passive loss limitations apply. We hold that, after applying the passive loss limitations, petitioners may deduct $50,000 in 1988 and $52,692 in 1989. (2) Whether petitioners' net capital gains were $227,720 for 1988 and $244,489 for 1989, as petitioners contend, or $257,720 for 1988 and $274,489 for 1989, as respondent contends. We hold that petitioners' net capital gains were $257,720 for 1988 and $274,489 for 1989. (3) Whether petitioners may carry forward net operating losses of $2,512,307 for 1988 and $2,401,099 for 1989. We hold that they may not. (4) Whether petitioners may deduct expenses relating to a dirt fill operation of $127,985 for 1988 and $135,824 for 1989. We hold that they may not. (5) Whether petitioners may claim a general business credit carryforward of $27,548 for 1988 and 1989. We hold that they may not. (6) Whether petitioners are liable for the addition to tax for substantial understatement of income tax under section 6661Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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