- 7 - Petitioner made payments as necessary to be released from personal liability under the settlement agreement, but the payments fell short of discharging Pacer’s total liabilities. In the summer of 1990, NAC seized the manufacturing equipment. Petitioners made delinquent filing of their Federal income tax returns for taxable years 1988 and 1989 on February 15, 1991. Their Federal income tax returns for taxable years 1990 and 1991 were filed on October 21, 1991, and October 19, 1992, respectively. Petitioners filed Schedules C, Profit or Loss from Business, for businesses described as “equipment rental” for taxable years 1988, 1989, and 1990, and as “metal fabrication” for 1991. On these Schedules C, petitioners reported no income but claimed deductions in the following amounts: 1988 1989 1990 1991 Depreciation $25,591 $51,151 $51,151 $31,942 Interest 15,278 -– -– -– Freight 1,320 –- -– –- Repairs 670 –- 5,897 –- Utilities/phone 2,000 -– -– -– Respondent disallowed these claimed deductions on grounds that petitioners had not established that they were engaged in the trade or business of equipment rental or metal fabrication, or that they had any basis in any assets relating to such activities.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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