- 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 NextLast modified: May 25, 2011