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David D. Aughtry, Lawrence Sherlock, and Linda S. Paine, for
petitioners.
David Delduco and Elizabeth B. Williamson, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court fully
stipulated. See Rule 122.1 Respondent determined a $281,556
deficiency in the 1994 Federal income tax of Henry A. Lassiter
and Ann M. Lassiter (Mr. Lassiter and Ms. Lassiter, respectively;
the Lassiters, collectively) and a $56,311 addition thereto under
section 6662. Following respondent’s concession that petitioners
are not liable for the addition to tax, we must decide whether
Mr. Lassiter, upon termination of his bankruptcy estate,
succeeded to any net operating losses (NOLs) from the estate
which the Lassiters may use to calculate their 1994 joint Federal
income tax liability. We hold he did.
Background
The stipulation of facts and the attached exhibits are
incorporated herein. The stipulated facts are found accordingly.
The Lassiters were married until Mr. Lassiter died on May 9,
1994, and Ms. Lassiter, in her own right and as administratrix of
1 Unless otherwise noted, Rule references are to the Tax
Court Rules of Practice and Procedure, and section references are
to the Internal Revenue Code in effect for the year in issue.
Bankruptcy Code references are to 11 U.S.C.(2000).
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Last modified: May 25, 2011