- 34 - 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 thePage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
Last modified: May 25, 2011