25 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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