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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
petition.
Background
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.
Plante.
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
business.
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