- 8 - The corporation has not defaulted on the loans. The Guarantors Petitioner’s father testified that he agreed to act as guarantor: “To expedite the loan and, hopefully, get a little lower interest rate.” Petitioner’s father was not a shareholder, officer, or employee of the corporation. Petitioners’ Returns On petitioners’ Federal income tax returns for 1994 through 1996, petitioners claimed losses from the corporation of $39,621.25, $44,390.02, and $53,188.25, respectively. For 1994, petitioners claimed a net operating loss carryforward of $743.62 (the carryforward), which resulted from losses of the corporation for 1993 and prior years (both such carryforward and the losses from the corporation for 1994 through 1996 being referred to as “the losses”). The Notice The adjustments giving rise to the deficiencies in tax here in question are respondent’s disallowance of any deductions for the losses.1 Respondent’s grounds for such adjustments are that, 1 Inexplicably, respondent’s disallowance for 1995 is in the amount of $42,564, which is $1,825.02 less than the loss claimed by petitioners ($44,390.02). We shall sustain respondent’s determination of a deficiency with respect to 1995 only to the extent attributable to respondent’s disallowance, in the amount of $42,564.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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