- 9 - from Sanrio was reported on the Schedules C attached to petitioners' 1990 return. D. Petitioners' Explanation of Unreported Sanrio Income From 1978 to 1984 petitioners lived in Boise, Idaho, where they engaged in real estate transactions. In 1983, they acquired an interest in Regent Properties (Regent), a 40-acre real estate development in Boise. In 1984, petitioners stopped paying equity into Regent, which had generated losses for them. Since then, they have not been actively involved in the property. At trial, petitioner was unaware of Regent's status, although the Paus still held their interest in it. Since 1986, petitioners had wanted to take advantage of projected losses from Regent but had been unsuccessful, because their ordinary income could not be applied against capital losses from the property. Petitioner hoped to treat the $840,000 as a capital gain and to apply $300,000 to $350,000 of capital losses from Regent against it if and when such losses were realized. Petitioners deliberately did not report the $840,000 of income from Sanrio on their 1990 income tax return, because they wanted to wait until the losses were realized, in order to report the income and the losses simultaneously. Therefore, they thought it would be easier to file an amended return to report the additional income, rather than to report it on the original return for 1990 and later file an amended return to claim a large refund.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011