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(2) whether petitioner is entitled to a net operating loss
(NOL) carryback from 1988 to 1985 greater than the amount allowed
by respondent; and
(3) whether petitioner is entitled to deduct certain
expenses incurred in 1987.
If we decide that petitioner's tax returns for 1976, 1984,
and 1985 are not fraudulent, we must decide whether the periods
of limitations for these years have expired. If we conclude that
petitioner's tax returns for 1976, 1984, and 1985 are fraudulent,
we must decide the following issues:
(1) The fair market value of Strata Corp. (Strata) stock for
1985;
(2) the fair market value of an 18-acre parcel of real
estate located at 1450 Brown Road, Columbus, Ohio (Brown Road
property), and a 274+ acre parcel of land in McKean Township,
Licking County, Ohio (the Licking County property), for 1976;
(3) whether petitioner is entitled to certain depreciation
deductions for 1976;
(4) whether the "Riverview" sales are capital transactions
for 1985;
(5) whether petitioner is liable for interest on a
substantial understatement attributable to a tax-motivated
transaction for 1976 and 1985 pursuant to section 6621(d);
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