Robert R. Plante and Mary B. Plante - Page 14

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          year 1991 that ultimately results in a net operating loss                   
          carryover deduction for the year 1992; respondent disagrees on              
          virtually every point.  Neither party makes a distinction between           
          the portion of the $475,000 in unpaid advances represented by               
          notes and the remaining portion.4                                           
               But for the advances evidenced by the notes, there is                  
          little, if any, evidence in the record regarding the details of             
          any other transaction(s) that account for the $155,000 difference           
          between the face value of the notes and the stipulated amount of            
          the unpaid advances.  As we have often stated, deductions are a             
          matter of legislative grace.  A taxpayer who claims a deduction             
          must identify the specific statute that allows for the deduction            
          and demonstrate that all of the requirements of the statute have            
          been satisfied.  Rule 142(a); INDOPCO, Inc. v. Commissioner, 503            
          U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S.             
          435, 440 (1934).  Having provided the Court with virtually no               
          information regarding $155,000 of the amount here in dispute,               
          petitioners have failed to establish that the requirements of               
          section 166 have been satisfied with respect to that amount.  On            

               4The parties stipulated that as of Nov. 1, 1991, "the                  
          petitioner had unpaid advances to the corporation totaling                  
          $475,000".  The preamble to the stipulation states that                     
          respondent "does not stipulate and agree by the use of the terms            
          'note,' 'loan,' or 'advance' in this stipulation or annexed                 
          exhibits that amounts paid to or on behalf of * * * [BCBI] by               
          petitioner * * * constituted loans for federal income tax                   

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