- 3 - 3. Whether, as petitioners contend, under section 706(d), GSD’s loss for 1991 is allocated pro rata to petitioner from January 1 to July 11, 1991, and to his bankruptcy estate and Martha Johnston from July 12 to December 31, 1991. We hold that none of GSD’s loss for 1991 is allocated to petitioner. 4. Whether, as petitioners contend, the bankruptcy trustee abandoned the administration of the bankruptcy estate’s GSD interest so that, under 11 U.S.C. section 554 (1988), the GSD interest reverted back to petitioner as if it had not entered the bankruptcy estate. We hold that the bankruptcy trustee did not abandon the GSD interest. 5. Whether any of the 1991 NOL survived after the NOL was reduced, pursuant to section 108, by the amount of cancellation of indebtedness income excluded from gross income. We hold that none did. Unless otherwise provided, section references are to the Internal Revenue Code in effect during the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioners Petitioners were married in 1993 and lived in San Antonio, Texas, when they filed their petition in this case. Petitioner was married to Martha R. Johnston (Johnston) (formerly known asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011