- 18 - The $564,189.13 amount that petitioners reported as gross receipts on their 1983 tax return represents the amount that Laney believed his clients had spent on R.K., both the actual outlays of his clients and the value of the time of his clients’ personnel. This amount does not include any amounts that Laney’s clients paid to him. The claimed $16,347,250 theft/casualty loss deduction includes some $480-490 thousand that petitioners had omitted from gross income over the period 1977 through 1982 and had spent on R.K. Petitioners chose not to carry back their claimed 1983 net operating loss, but instead to carry it only forward, and attached statements to this effect to their 1983 and later tax returns. Table 2 summarizes information appearing on the first and second pages of petitioner’s tax returns for 1977 through 1988.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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