- 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.
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