- 6 - on the CIS, under the category “Other information relating to your financial condition”, that there were no court proceedings or repossessions. Petitioner’s Claimed Net Operating Loss Deduction For taxable year 1993, petitioners claimed a net operating loss deduction of $3,992,234, comprising net operating loss carryovers from prior years in the following amounts: Year Amount 1986 $134,414 1987 424,283 1988 306,907 1989 1,627,007 1990 1,417,445 1991 82,178 3,992,234 Respondent’s Determinations Respondent determined that for taxable year 1993 petitioners had unreported ordinary income of $2,781,810 from discharge of the debts owed by petitioner to Bonnevista and Castle Towers.8 Respondent also disallowed petitioners’ claimed net operating loss deduction. 8 The notice of deficiency charges petitioner with unreported cancellation of indebtedness income based on the $2,148,481 loan due from petitioner to Bonnevista at the beginning of 1991, rather than the $2,244,164 due at the end of 1991. On brief, respondent states that although the facts support using the larger, more recent, loan balance to compute petitioner’s 1993 cancellation of indebtedness income, respondent has not amended his position to assert an increased deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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