Aron B. Katz and Phyllis A. Katz - Page 4




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          The prepetition items were specifically allocated to Mr. Katz in            
          his individual capacity, while the postpetition items were                  
          allocated to Mr. Katz’ bankruptcy estate.                                   
               A number of partnerships, however, made no attempt to                  
          subdivide the 1990 calendar year distributive share between Mr.             
          Katz and his bankruptcy estate.  Rather, each of these                      
          partnerships issued a Schedule K-1, Partner’s Share of Income,              
          Credits, Deductions, etc., to Mr. Katz reflecting the entire 1990           
          calendar year distributive share.  With respect to these                    
          partnerships, Mr. Katz undertook an interim closing of the books            
          on their behalf, allocating the prepetition items to himself and            
          the postpetition items to his bankruptcy estate.  Mr. Katz                  
          explained each such allocation through a Form 8082, Notice of               
          Inconsistent Treatment or Administrative Adjustment Request                 
          (AAR), attached to his 1990 tax return.                                     
               The prepetition items from the 1990 calendar year                      
          distributive shares which were allocated to Mr. Katz in the                 
          manner described above resulted in losses totaling $19,122,838              
          (the prepetition partnership losses).3  This amount made up most            
          of the $19,262,795 net operating loss (NOL) Mr. Katz reported for           
          his 1990 taxable year.                                                      

               3  The bulk of the prepetition partnership losses was                  
          generated by a partnership entitled Century Centre Associates,              
          Ltd.  This partnership allocated $18,569,842 of overall loss to             
          Mr. Katz with respect to the period prior to July 5, 1990, while            
          allocating to Mr. Katz’ bankruptcy estate $33,381,880 of overall            
          income with respect to the remainder of 1990.                               




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