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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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