- 4 - year 1991, and in the amount of $3,288 for the tax year 1992;6 and (6) whether petitioners are entitled to a claimed deduction for office expenses in the amount of $958 for the tax year 1992, attributable to their horse-breeding activity. FINDINGS OF FACT Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of filing the petitions, petitioners' mailing address was located at Franktown, Virginia. 1. Petitioner Charles F. Patterson's Net Operating Loss On his 1991 return, petitioner Charles F. Patterson claimed an NOL carryover, purportedly attributable to the tax years 1988 through 1990, in the amount of $113,259. Upon examination, respondent disallowed the claimed NOL carryover. Respondent argues that petitioner has failed to substantiate the loss in question. The record does not contain petitioner's returns for the tax years 1988 through 1990. 6 On their respective 1991 returns, petitioners each claimed depreciation expenses in the amount of $7,255. After respondent's concession in the amount of $1,405, and each petitioner's concession in the amount of $900, the amount of depreciation remaining in dispute, with respect to each petitioner, is $4,950. On their 1992 return, petitioners claimed depreciation expenses in the amount of $8,166. After respondent's concession in the amount of $5,622, petitioners' concession in the amount of $155, and petitioners' claim for additional depreciation in the amount of $899, the amount of depreciation remaining in dispute is $3,288.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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