- 9 - Petitioners did not introduce a copy of their 1980 Federal income tax return to show how they treated the Arizona Marine transaction. Petitioners put "everything" they received from Arizona Marine and Riviera "in the same storage deal". Petitioner husband testified "I just figured I could probably sell it and get my money back." At some point, petitioners leased the molds to other boat builders. Eventually, petitioners got the molds back from the lessees. In 1985, petitioners claimed the $205,029 nonbusiness bad debt deduction for the Arizona Marine and Riviera assets because petitioners "perceived no value in that stuff at all at that point in time." Petitioner husband further testified that in 1985, he came to the conclusion that: I was not going to get any money out of this equipment and there was two things that happened here, Your Honor. One is I had gone through an audit in like 1976 with the IRS. When the IRS got through with the audit, I ended up with a $32,000 tax credit and I had never used all that tax credit up. So when I shut [Riviera] down and Arizona Marine at the time, the losses, I mean, I couldn't use them. So in 1985 was the first time that I could even use any of these losses. So determining that there was no value to any of that equipment or stuff left, I went ahead and put it on my income tax in 1985. Subsequent years in '86 and '87 I sold some of the stuff and, if you'll look at those tax returns, you'll see I reported the income I received from the sale of that equipment and molds. Petitioners received $20,000 in 1986 and $25,000 in 1988 from these sales. Other than petitioner husband's generalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011