- 8 - ducted in their respective returns for 1991, 1992, and 1993 only a portion of the total amounts of investment interest claimed in their respective Forms 4952 for those years. Pursuant to section 163(d)(2), they treated the balance of the total amount of investment interest claimed in Forms 4952 for each of the years 1991 and 1992 as disallowed investment interest to be carried over to the succeeding taxable year. In Schedules A, Itemized Deductions (Schedule A), of their returns for 1991, 1992, and 1993, petitioners claimed total interest deductions of $179,235, $141,388, and $96,901, respec- tively. Those deductions consisted of the following claimed amounts of interest for the taxable years indicated: Claimed Taxable Home Mortgage Claimed Year Interest and Points Investment Interest 1991 $22,527 $156,708 1992 19,280 122,108 1993 15,744 81,157 In Schedule D, Capital Gains and Losses (Schedule D), of their 1992 return, petitioners claimed a net long-term capital loss of $194,118. Included in the computation of that loss was a claimed long-term capital loss of $289,316 (claimed 1992 worth- less stock loss) that petitioners explained in a statement attached to their 1992 return as follows: "The National Bank of Harrah Common Stock was evaluated in June, 1992 and determined to be worthless in accordance with Internal Revenue Code SectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011