Robert A. Read - Page 3

                                        - 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

Last modified: May 25, 2011