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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).
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Last modified: May 25, 2011