- 17 - Springs’ 1991 Federal partnership income tax return of $2,321,014. On L&C Springs' 1991 Federal partnership income tax return, it was indicated that, because "the apartment buildings in Miami Springs, Florida, are in bankruptcy" the records necessary to report L&C Springs' net operating losses and other expenses could not be located, and therefore no net operating losses or depreciation expenses were reported and deducted relating to the L&C Properties. It does not appear from the record that L&C Springs ever filed an amended 1991 Federal partnership income tax return claiming any 1991 net operating losses, accrued interest, or depreciation expenses relating to the L&C Properties. The following schedule reflects net losses and related interest and depreciation expenses relating to the L&C Properties as claimed by L&C Springs for 1987 through 1990. As Claimed By L&C Springs Income Interest Depreciation Year (Loss) Expense Expense 1987 $(278,646) $(250,075) $(164,855) 1988 (328,373) (254,413) (168,350) 1989 (350,570) (264,858) (167,707) 1990 (301,033) (261,961) (167,722) On audit for 1987, not now before the Court, respondent, on April 5, 1991, issued an FPAA to L&C Springs charging L&C Springs with $2,250,000 in ordinary income on the ground that L&C Springs effectively abandoned to Tanglewood its ownership interest in thePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011