Alton W. Burns and Pamela Burns - Page 9

                                                 - 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 general                                   





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011