- 3 - For the taxable year 1984, petitioner timely filed an individual Federal income tax return. He also filed two amended 1984 Federal income tax returns dated November 25, 1991, and May 11, 1992. For the taxable year 1986, petitioner timely filed an individual Federal income tax return. On his 1986 return, petitioner claimed a business bad debt deduction of $874,177. Because of the bad debt deduction and other losses not at issue in this case, petitioner claimed a NOL carryback from 1986 to 1984 in the amount of $868,612, as set forth on his second amended 1984 return. Respondent disallowed the 1986 bad debt deduction and the resulting NOL carryback. 1982 $1 Million Loan from Guaranty National Bank On August 20, 1982, VIP Investors (VIP), an Oklahoma limited partnership, was formed to buy a Sheraton Hotel in Oklahoma City, Oklahoma. On that date, a limited partnership agreement was signed by the general partner, Terminal Drive Corp. (Terminal), and by the 10 limited partners, one of whom was petitioner. At that time, Terminal owned 10 percent of VIP, petitioner owned 45 percent, and the other limited partners together owned the remaining 45 percent of VIP. Also on that date, VIP borrowed $1 million from Guaranty National Bank (Guaranty) in order to purchase the Sheraton Hotel. 1984 Loan From Security Bank On August 1, 1984, Terminal sold its 10-percent interest to petitioner and assigned him its general partnership interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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