Earl E. Cloud, Jr. and Sheila S. Cloud - Page 7




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               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.                                                                 










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