Clinton N. and Naomi K. Bohannon - Page 25

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            regarding the net operating loss carryovers were not offered into                           
            evidence.  We have only his testimony about the net operating                               
            loss calculations.  He did not explain how he computed                                      
            petitioners' net operating loss carryforward, or why he computed                            
            net operating loss carryforwards different from those claimed                               
            ($2,512,307 for 1988 and $2,401,099 for 1989) on petitioners'                               
            returns for 1988 and 1989.  His general testimony that                                      
            petitioners' and Bob Wade Ford's returns are true and correct                               
            does not establish that petitioners had net operating loss                                  
            carryforwards for 1988 and 1989.                                                            
                  We agree with respondent on this issue because petitioners                            
            did not show that they had net operating losses from 1982 to 1987                           
            or that those losses were not absorbed in prior years.  See                                 
            McWilliams v. Commissioner, T.C. Memo. 1995-454 (Court rejected                             
            taxpayers' claimed carryover losses since they did not show that                            
            the losses were not absorbed in prior years).                                               
            E.    General Business Credit                                                               
                  Petitioners reported but did not claim a $27,548                                      
            carryforward of the general business credit on their 1988 and                               
            1989 returns.  Kane testified that the general business credit                              
            reported on petitioners' 1988 and 1989 returns was a carryforward                           
            of petitioners' distributive share of investment tax credits                                
            reported by Bob Wade Ford.                                                                  








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