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Petitioners object to respondent's computation of the
deficiency in, and additions to, petitioners' 1984 tax on
two grounds. First, respondent failed to give petitioners
any credit in 1984 for taxes paid with respect to the
income from the Roscrea Trust reported on their returns for
the years 1987 through 1990. Petitioners refer to income
from the Trust that was reported on their returns for the
years 1987 through 1990 as "phantom income". Second,
respondent failed to recognize in computing petitioners'
1984 taxes the "economic loss" of $57,420 that petitioners
suffered by reason of their cash investment in the Roscrea
Trust.
Petitioners ask the Court to order respondent to take
those items into account (i.e., "phantom income" reported
for the years 1987 through 1990 and petitioners' cash
investment) in computing their liability for taxes,
interest, additions, and penalties with respect to the
year in issue in this case, 1984, and the years in issue
in other docketed cases, 1982, 1983, and 1985. According
to petitioners, their request "is consistent with this
Court's inherent powers, general equitable principles, and
clear Congressional intent--as well as common sense notions
of judicial economy and sound tax administration."
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