T.C. Memo. 1997-403 UNITED STATES TAX COURT MELVIN J. LANEY AND CAROLYN A. LANEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24510-90. Filed September 11, 1997. Petitioners (Ps) claimed on the Schedule C of their 1983 tax return a $16.3 million “theft/casualty” loss. Ps carried forward this loss as a net operating loss to their 1986, 1987, and 1988 tax returns. Ps contend they are entitled to the claimed deductions, even if the deductions are not otherwise allowable, because of a settlement agreement with the Department of Justice in connection with a suit in the Court of Claims. Ps also contend that they had a binding settlement agreement with the Internal Revenue Service in the instant case, allowing a net operating loss of more than $0.5 million. 1. Held: Ps did not have a settlement agreement with either the Department of Justice or the Internal Revenue Service. 2. Held, further, Ps are not entitled to loss carryover deductions on account of theft, casualty, orPage: 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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