- 12 - For each year in issue, Dr. Beck claimed net operating loss (NOL) carryovers as follows: Year NOL Carryover 1991 $367,251 1992 318,145 1993 377,950 1994 408,759 1995 424,310 Notices of Deficiency In the notice of deficiency issued to Dr. Beck, respondent determined that Dr. Beck had claimed and failed to substantiate certain Schedule C deductions as follows: Claimed Respondent’s Deductible Determination of Adjustment to Year Expenses Deductible Expenses Taxable Income 1991 $382,205 $88,407 $293,798 1992 591,436 270,839 320,597 1993 1542,044 288,668 253,376 1994 1600,159 247,194 352,965 1995 377,218 110,174 267,044 1 As previously indicated, for years 1993 and 1994, petitioner’s claimed Schedule C deductions were $529,114 and $585,831, respectively. In the notice of deficiency, respondent appears to have overstated the amounts of deductions claimed by Dr. Beck for 1993 and 1994, resulting in excessive adjustments to taxable income for these 2 years. We expect these errors to be corrected in the Rule 155 computation. Based on these adjustments, respondent redetermined Dr. Beck’s Schedule C income for each year in issue and allocated one-half of that income, along with one-half of Schedule E royalty income reported by Dr. Beck for each year in issue, to Mrs. Beck as her community property income. Accordingly, in separate notices of deficiency, respondent determined that Mrs.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011