Melvyn L. Bell - Page 2

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               After concessions, the issues for our consideration are:               
          (1) Whether petitioners are entitled to a business bad debt                 
          deduction in 1988 under section 1661 and to the carryback of the            
          resulting 1988 net operating loss to the 1985 and 1986 taxable              
          years, and (2) whether petitioner Darlene K. Carvin is entitled             
          to relief as an innocent spouse under section 6013(e).                      
                                  FINDINGS OF FACT2                                   
               At the time the petitions in these consolidated cases were             
          filed, petitioner Melvyn L. Bell and petitioner Darlene K.                  
          Carvin, formerly Darlene C. Bell, resided in Little Rock,                   
          Arkansas.  During the years in issue, petitioners were married              
          and filed joint Federal income tax returns.  Petitioners divorced           
          in 1991.                                                                    
               Melvyn L. Bell (petitioner) received a bachelor's degree in            
          electrical engineering in 1960.  He had started working for an              
          engineering firm in 1959 and later became a partner in the firm.            
          Throughout his engineering career, petitioner was involved in a             
          number of business ventures.  In the latter part of 1959,                   
          petitioner had cofounded Data Testing, Inc., a company that                 
          tested soils, asphalts, and concrete.  The company later merged             
          with the engineering firm.  A couple of years after he began                


               1 Unless otherwise stated, all section references are to the           
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               2 The stipulation of facts and attached exhibits are                   
          incorporated herein by this reference.                                      


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