- 19 - held for sale in the ordinary course of that trade or business, or that petitioner was engaged in a trade or business of developing and promoting businesses and that Hidden Valley was held pursuant to that trade or business. We have already rejected these arguments and do not need to address them again in detail. Accordingly, the $1,643,900 loss petitioners sustained in 1989 relating to Hidden Valley is a long-term capital loss.8 For the foregoing reasons, Decision will be entered under Rule 155. 8 Furthermore, in claiming the Hidden Valley loss as ordinary on their 1989 Federal income tax return, petitioners assert that there is a resulting net operating loss. Petitioners assert that this net operating loss should be carried back to 1986, 1987, and 1988, and applied against the deficiencies determined by respondent. Since we have held that the Hidden Valley loss is capital, we do not reach this issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011