- 7 -
was ever received from the IRS if it was filed. As
stated above, it was Ms. Reed's intention to have Spirit
Horse Ranch, Inc. be an S Corporation from it's [sic]
inception in 1986 even though there is no evidence of a
Form 2553 being prepared until 1989.
* * * * * * *
* * * it is requested that the election as an S
Corporation by Spirit Horse Ranch, Inc. effective for the
calendar year ending December 31, 1986 be validated and
the taxpayer be promptly notified of the decision. In
the alternative it is requested that the election be
validated for the calendar year ending December 31, 1990
as shown on the Form 2553.
Petitioner signed the letter acknowledging its content and
accuracy. As of the date of trial, the IRS had not responded to
petitioner's request.
Federal Tax Returns
Petitioner filed her 1988 through 1993 Federal income tax
returns in February 1997. Petitioner's 1988 tax return reported
adjusted gross income of negative $97,376, which included farm
losses from her cattle-ranching activities on Schedule F (Profit or
Loss From Farming) of $67,904; the 1989 tax return reported
adjusted gross income of negative $62,337, which included farm
losses on Schedule F of $61,960; the 1990 tax return reported
adjusted gross income of $42,247, which included farm losses on
Schedule F of $44,838; the 1991 tax return reported adjusted gross
income of $13,250, which included farm losses on Schedule F of
$35,992; the 1992 tax return reported adjusted gross income of
$109,928, which included farm losses on Schedule F of $33,060; and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011