Clinton N. and Naomi K. Bohannon - Page 2

                                                   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 6661                             




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