Charles B. Owens and Sally L. Owens - Page 4




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          Petitioners’ Returns                                                        
               Petitioners made a joint return of Federal income tax for              
          1994 by filing a Form 1040, U.S. Individual Income Tax Return               
          (the 1994 return).  On line 21 of the 1994 return (“Other                   
          income”), petitioners reported a negative amount, $354,495.  In a           
          statement supporting that entry, petitioners, among other things,           
          (1) reported $1,338,924 as an item of income, labeled “FDIC-                
          SOUTHWEST SERVICE CENTER-Form 1099-C”, (2) subtracted an equal              
          amount, labeled “ERRONEOUS 1099-C – DEBT NOT DISCHARGED”, and               
          (3) subtracted $390,173 as a net operating loss (NOL) deduction.            
          That NOL deduction consisted of NOL carryovers from 1986, 1990,             
          and 1993.                                                                   
               Petitioners made a joint return of Federal income tax for              
          1996 by filing a Form 1040, U.S. Individual Income Tax Return               
          (the 1996 return).  On line 21 of the 1996 return (“Other                   
          income”), petitioners reported a negative amount, $118,961.  In a           
          statement supporting that entry, petitioners, among other things,           
          subtracted $137,033 as an NOL deduction.  That NOL deduction                
          consisted of NOL carryovers from 1990 and 1993.                             
          Respondent’s Examination                                                    
               Respondent undertook an examination of the 1994 return.                
          During the course of that examination, respondent summoned the              
          FDIC to produce all documentation relating to the loan.  The                
          ensuing FDIC correspondence to respondent (the FDIC                         




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