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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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