Robert L. Beck - Page 12




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               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.             





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