Robert R. Plante and Mary B. Plante - Page 2

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              In a notice of deficiency issued to petitioners on                     
          September 27, 1995, respondent determined a deficiency in their             
          1992 Federal income tax in the amount of $8,849.  The issue for             
          decision is whether petitioners are entitled to a net operating             
          loss carryover deduction for the year 1992.  The resolution of              
          this issue depends upon whether petitioners suffered a net                  
          operating loss for the year 1991, which in turn depends upon                
          whether petitioners are entitled to a business bad debt deduction           
          for that year, claim for which was made for the first time in the           
               Petitioners filed a joint Federal income tax return for the            
          year 1992.  At the time that the petition was filed they resided            
          in Cumming, Georgia.  References to petitioner are to Robert R.             
               After his graduation from Harvard University in 1962,                  
          petitioner worked for various companies in the packaging                    
          industry, including Boise Cascade, Continental Can, and Maryland            
          Cup Corp.  At the time petitioner was employed by Maryland Cup              
          Corp. petitioners lived in the Baltimore, Maryland, area.  When             
          Maryland Cup Corp. announced plans to relocate to Green Bay,                
          Wisconsin, petitioner rather than transfer, resigned from the               
          company with the intent to invest in and manage a marina                    

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