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Great Northern Development Co. Trust (GND), Daniel A.
Carvalho, Trustee:
Penalty
Year Deficiency Sec. 6662(a)
1996 $110,123 $20,025
1997 138,529 27,706
Worldwide Travelers Trust (WT), Daniel A. Carvalho, Trustee:
Penalty
Year Deficiency Sec. 6662(a)
1996 $102,685 $20,537
1997 138,394 27,679
Golden Nugget Investments Co. Trust (GNI), Daniel A.
Carvalho, Trustee:
Penalty
Year Deficiency Sec. 6662(a)
1996 $78,013 $82,873
1997 15,603 16,575
Background
In the Wards’ notice of deficiency, respondent determined:
(1) The amount the Wards could claim for their exemptions in 1996
and 1997 was reduced to zero because of the amount of their
income; (2) the Wards’ itemized deductions for 1996 and 1997 were
decreased by $38,043 and $25,096, respectively, because they
failed to establish that $24,783 for 1996 and $12,285 for 1997
were losses sustained by them and because their itemized
deductions were limited because of the amount of their adjusted
gross income; (3) the Wards’ Schedule C, Profit or Loss From
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Last modified: May 25, 2011