- 6 - reflected on their 1991 through 1994 joint Federal income tax returns. Petitioners argue that through a reconstruction of their records they have adequately established and substantiated the claimed NOL carryovers. Petitioners also assert that under section 108 only a small portion of the claimed NOL carryovers would be eliminated. With limited exceptions, petitioners' Federal income tax returns and records relating to 1980 through 1989 were not introduced into evidence. Petitioners' testimony is inconsistent and not credible. Based on the evidence, we hold that petitioners have not met their burden of substantiating the claimed NOL carryovers, and we sustain respondent's disallowance thereof. Apparent copies of petitioners' Federal income tax returns for 1980, 1987, and 1988 are in evidence and show claimed NOL's. No further books and records or credible evidence, however, support the claimed NOL's. Petitioners allege that copies of their income tax returns were stolen from their rental storage unit. Petitioners' report of the theft, however, did not indicate any loss of petitioners' income tax returns or records. Petitioner testified that his mother had custody of records relating to the farm and to petitioners' oil and gas activities and that petitioners' reconstruction of their income tax returnsPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011