Gerald Q. and Patricia R. Ashbrook - Page 4




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          petitioner indicated that the only property stolen was a tool               
          chest.                                                                      
               On May 29, 1991, petitioner's bankruptcy proceedings were              
          closed.                                                                     
               On April 18, 1994, petitioners untimely filed their 1991               
          joint Federal income tax return.                                            
               On February 27, 1995, petitioners untimely filed their 1992            
          and 1993 joint Federal income tax returns.                                  
               On October 15, 1995, petitioners timely filed their 1994               
          joint Federal income tax return.                                            
               On their 1991 through 1994 joint Federal income tax returns,           
          petitioners claimed NOL carryovers that purportedly originated              
          primarily in 1987 and prior years as follows:                               

               Tax Return               NOL Carryovers Claimed                        
                         1991           $225,127                                      
                         1992           174,729                                       
                         1993           106,089                                       
                         1994           31,784                                        

               On their 1991 through 1994 joint Federal income tax returns,           
          after applying the above claimed NOL carryovers, petitioners' net           
          taxable income or net losses were reflected as follows:                     
                      Tax Return      Taxable Income or Loss                         
                   1991            ($186,017)                                         
                     1992          (118,378)                                          
                     1993          (36,484)                                           
                     1994          10,461                                             








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