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petitioners are not entitled to any loss carrybacks from 1990 to
1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioners resided in
Trumbull, Connecticut, when they filed their petition.
Mrs. Hovhannissian thereafter died, and her estate was
substituted as a party to this proceeding.
Beginning in 1953, petitioner acquired several contiguous
parcels of land in Bridgeport, Connecticut (hereinafter 225-235
Boston Avenue property and 245 Boston Avenue property), upon
which he built several structures. Petitioner operated a retail
carpet and furniture business on the premises from the time of
their construction until he sold the 225-235 Boston Avenue
property in 1988. Petitioner continued to operate a carpet
business at the 245 Boston Avenue property through at least 1990.
In 1972, petitioner began to build a combination parking
garage and warehouse on the rear portion of the 225-235 Boston
Avenue property. Petitioner encountered various difficulties in
building this structure, which was never completed or put into
service. Petitioner estimated that he spent $400,000 in
constructing this structure, but lost his records of the
construction costs. Petitioner submitted an expert report that
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