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Issue 24. Whether IRA Is Entitled to a Charitable Contribution
Carryover Deduction for 1983
OPINION
In the notice of deficiency for 1983, respondent determined
that IRA was not entitled to a charitable contribution carryover
in the amount of $203. Because the charitable contribution
deductions were allowed in prior years, there was no carryover
from 1982 to 1983. IRA did not introduce any evidence on this
issue. Therefore, we sustain respondent's determination.
Issue 25. Whether IRA Is Entitled to Certain Claimed Capital
Losses for 1985
FINDINGS OF FACT
On its Federal income tax return for 1985, IRA claimed
capital losses of $766,566 on the purported sales or other
dispositions of certain assets as follows:
Gross
Date Date Sale
Description Acquired Sold Price Basis Loss
Brajda's 5/14/85 3/18/85 $19,388 $58,251 ($38,863)
N/R Funding Sys. 7/82 12/01/85 20,000 91,988 (71,988)
N/R Tanglewood 7/11/80 12/01/85 10,000 350,000 (340,000)
N/R LBG 9/83 12/01/85 10 39,500 (39,490)
N/R Sherwood 10/84 12/01/85 1,000 47,925 (46,925)
U.S. Mineral 7/13/81 12/01/85 500 87,700 (87,200)
Comp. Container 2/25/83 12/01/85 25,000 115,000 (90,000)
Modular Power 3/18/83 12/01/85 100 12,200 (12,100)
Forenergy 12/83 12/01/85 5,000 45,000 (40,000)
Total 80,998 847,564 (766,566)
In the notice of deficiency, respondent disallowed the
claimed losses on the grounds that IRA did not establish its
basis in the assets sold or disposed of and IRA did not
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