- 23 - Petitioners’ failure to file their 1987 income tax return until May 11, 1989, was not due to reasonable cause. Petitioners substantially understated their income tax liabilities for 1986, 1987, and 1988; however, they adequately disclosed in a statement attached to their tax returns the relevant facts affecting the tax treatment of their claimed net operating loss carryforward. OPINION Every matter that we are to resolve in the instant case stems directly from, or is substantially affected by, R.K. I. Settlement A. With Justice Department Petitioners argue that they are entitled to a 1983 theft/casualty loss deduction with a 15-year net operating loss carryover because Laney had an agreement with the Department of Justice that he is entitled to deduct this net operating loss carryover in exchange for voluntarily dismissing the Court of Claims petition in which he alleged a taking of R.K. by the United States. Respondent contends that petitioners did not have an agreement with the Department of Justice. We agree with respondent. In their pretrial memorandum, the first witness petitioners listed was Henry, who was expected to testify about “thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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