Clinton N. and Naomi K. Bohannon - Page 24

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            unreported income before 1988 and even if we assume that they                               
            could deduct a casualty loss and exclude income under section                               
            911.                                                                                        
                  Petitioner testified that petitioners' returns for 1982 to                            
            1989 were true and correct.  His testimony does not convince us                             
            that petitioners are eligible for net operating loss                                        
            carryforwards to 1988 and 1989.  A tax return does not establish                            
            the correctness of the facts stated in it.  Seaboard Commercial                             
            Corp. v. Commissioner, 28 T.C. 1034, 1051 (1957); see Wilkinson                             
            v. Commissioner, 71 T.C. 633, 639 (1979); Roberts v.                                        
            Commissioner, 62 T.C. 834, 837 (1974).  As we stated above,                                 
            petitioner's testimony was often evasive, vague, and not                                    
            credible, yet petitioners ask us to accept (without any records)                            
            his testimony that their tax returns for 10 to 15 years were true                           
            and accurate.  We are not bound to accept the testimony of a                                
            taxpayer under these circumstances.  Hradesky v. Commissioner, 65                           
            T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.                                 
            1976).                                                                                      
                  Kane testified that petitioners' net operating loss                                   
            carryover was $1,706,535 at the end of 1988 and $1,555,655 at the                           
            end of 1989.  He did not testify about the net operating loss                               
            carryover available at the end of 1987.  The only indication of                             
            the net operating loss carryforward to 1988 is the amount                                   
            petitioners claimed on their 1988 return.  Kane's worksheets                                






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