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petitioners’ Maryland income taxes for 1983, 1984, and 1985. In
its opinion the Maryland Tax Court concluded that petitioners
lost $563,784 in 1983 on account of the foreclosure sale of the
Island.
Petitioners did not enter into a binding settlement
agreement with the Department of Justice in connection with
Laney’s Court of Claims suit.
Petitioners and respondent did not have a binding settlement
agreement in the instant case, nor did they enter into a section
7121 agreement with respect to the instant case or any issue
therein.
The Army Corp of Engineers did not criminally appropriate
the Island or any other asset connected with R.K. Poppe did not
criminally appropriate the Island or any other asset connected
with R.K.
R.K. was not part of Laney’s trade or business of offering
his services as a consultant. R.K. had not gone into operation
before Laney suffered his losses and was forced to give up the
Island and the entire project.
Petitioners did not use due care in claiming the $16.3
million theft and casualty loss with a 15-year net operating loss
carryforward; and they failed to do what a reasonable and
ordinarily prudent person would do under the circumstances.
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