- 5 - II. Allied Electric Business Deductions A. Net Operating Loss Carryforwards Petitioner contends, but failed to establish, that his 1994 income is offset by net operating losses. See Jones v. Commissioner, 25 T.C. 1100, 1104 (1956)(holding that a taxpayer must prove the amount of the net operating loss carryforward deductions claimed and that his gross income in other years did not offset those losses), revd. and remanded on other grounds 259 F.2d 300 (5th Cir. 1958). Petitioner’s documentary evidence consisted of his tax returns and a worksheet with figures differing from those on the returns. See Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979)(holding that tax returns alone do not establish a taxpayer’s entitlement to claimed deductions). Respondent concedes petitioner had eligible net operating losses of $15,546, $3,577, $35,791, and $9,573 in 1982, 1989, 1991, and 1992, respectively. These losses were absorbed by income in carryback and carryover years prior to 1994. See sec. 172(b)(stating that net operating losses must be carried back 3 years and the remaining portion carried forward 15 years). Accordingly, petitioner does not have a net operating loss carryforward in 1994. B. Additional Business Depreciation Petitioner failed to establish that the Lincoln Town Car was used for business purposes. We conclude, however, that thePage: Previous 1 2 3 4 5 6 Next
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