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did not receive this return, along with a further extension
request, until February 28, 1992.
On their 1990 joint Federal income tax return, petitioners
reported subpart F income of, among other entities, Guardian Bank
and deficits in the earnings and profits of Guardian Services and
Stanford Financial, as follows:
Deficits In
Subpart F Income Earnings & Profits
Guardian Bank $2,789,722 ---
Guardian Services --- ($1,251,891)
Stanford Financial --- ($ 154,474)
Total $2,789,722 ($1,406,365)
As indirect owners of Guardian Bank and as required under
section 951, petitioners reported on their 1990 joint Federal
income tax return the above $2,789,722 subpart F income of
Guardian Bank. On their 1990 joint Federal income tax return,
petitioners also reduced this subpart F income of Guardian Bank
by the above $1,406,365 total deficits in the 1990 earnings and
profits of Guardian Services and of Stanford Financial.
On their 1990 joint Federal income tax return, petitioners
also reported a $615,890 net operating loss carryforward
deduction from 1989, which net operating loss arose, in part,
from petitioners’ reduction of reported 1989 $580,483 subpart F
income of Guardian Bank by reported $385,386 total deficits in
1989 earnings and profits of Guardian Services and of Stanford
Financial.
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