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Unless otherwise indicated, 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.
After concessions, the issues for decision are whether
petitioners have substantiated claimed net operating losses
(NOL's) for 1980 through 1990 to carry forward to 1991 through
1994 and whether petitioners are liable for accuracy-related
penalties. All references to petitioner in the singular are to
Gerald Q. Ashbrook.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Corpus Christi, Texas.
In 1978, petitioner formed an accounting partnership with
Patricia Brink.
Beginning in 1979, petitioner participated with petitioner's
stepfather and mother (parents) and with H.T. and Holley Bailey
(the Baileys), unrelated individuals, in a farm and ranch joint
venture (the farm). The Baileys jointly held a 50-percent equity
interest in the farm. Petitioner's parents jointly held a 25-
percent equity interest in the farm, and petitioner held a 25-
percent equity interest in the farm. Petitioner's parents
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Last modified: May 25, 2011