Anthony G. and Shirley A. Olbres - Page 34

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          ceipts of Design Consultants, the unreported income for 1988 that           
          respondent determined in the notice included (1) the $49,525 of             
          1988 White Star compensation and (2) income resulting from the              
          disallowance by respondent of the net operating loss that peti-             
          tioners claimed for that year.  With respect to petitioners'                
          claimed net operating loss, two of the components that petition-            
          ers claim gave rise to that loss were a casualty loss resulting             
          from a fire at the Seabrook property on March 13, 1988, and a               
          Schedule E loss of $28,195 that petitioners claimed in their 1988           
          return.  With respect to petitioners' claimed casualty loss,                
          respondent determined that for 1988 petitioners had a gain of               
          $7,415, and not a loss, resulting from the fire at the Seabrook             
          property because the proceeds that petitioners received from                
          their insurance company as a result of that fire exceeded the               
          basis of the portion of the Seabrook property that the fire                 
          destroyed.  With respect to petitioners' claimed Schedule E loss            
          of $28,195, respondent determined that for 1988 petitioners had a           
          Schedule E gain of $60,930, and not a loss, because for that year           
          they had unreported rental income of $9,315, they overstated                
          their deductions with respect to their rental property by                   
          $32,531, and their income with respect to their S corporation               
          White Star was understated by $53,230.                                      
               Respondent's determinations in the notice of Design Consul-            
          tants' unreported gross receipts were based on the bank deposits            
          method analysis conducted by Mr. Kaply.  As is reflected in the             




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