- 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