- 3 - Background Petitioner is the Estate of Jack L. Bradley (the estate). John S. Bradley, successor executor, C.T.A., of the estate was a resident of the State of Washington at the time the petition herein was filed. Decedent (who died in 1989) and his wife (who died in 1986) filed joint Federal income tax returns for the taxable years 1982 and 1983. Decedent claimed net operating loss carrybacks from the taxable years 1985 and 1986 to the taxable years 1982 and 1983 attributable to deductions of loss and investment interest expense (the claimed deductions) relating to Hambrose Leasing 1984-5 (the partnership) in the following amounts: Original Year Carryback Year Amount 1985 1982 $309,869 1985 1983 150,730 1986 1983 386,066 This case involves two sale-leaseback transactions, among the following entities: Hambrose Leasing 1984-5, a partnership engaged in the equipment leasing business; Charterhouse Leasing Associates Limited Partnership (Charterhouse); Hambrose Reserve Ltd. (Hambrose); M & J Holding Corp. (M & J), the sole shareholder of Hambrose and the general partner of Charterhouse; CIS Leasing Corp. (CIS); and Comdisco, Inc. (Comdisco).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011