Oliver W. and Edna D. Wilson - Page 46




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               B. 5415 S. Broadway Property                                           
               As indicated previously, petitioners offered almost no                 
          evidence concerning their purported rental activity involving the           
          5415 S. Broadway property.  In addition, petitioners failed to              
          substantiate certain rental expenses that respondent had                    
          disallowed.  Consequently, we sustain respondent’s determinations           
          for 1992 and 1993 with respect to that property.  Rule 142(a)(1).           
               C. Prior Year Disallowed Passive Losses                                
               Petitioners have failed to establish that they are entitled            
          to deduct prior year unallowed passive losses of $1,345.                    
          Consequently, we sustain respondent’s determination disallowing             
          their deduction for 1993 of prior year passive losses.  Rule                
          142(a).                                                                     
          VI. 1992 and 1993 NOL Deductions                                            
               Petitioners claimed NOL deductions for 1992 and 1993 on the            
          basis of certain NOL carryforwards that petitioners had computed            
          from 1990 and 1991.  The 1990 and 1991 NOL carryforwards they had           
          computed arose from Schedule C expenses they deducted with                  
          respect to their purported nightclub/restaurant business at the             
          5401-9 S. Broadway property.  As discussed supra in part II,                
          petitioners had not opened and did not operate any restaurant or            
          nightclub on the property during 1990 and 1991.  In addition,               
          nearly all the 1990 and 1991 Schedule C expenses were direct and            
          indirect costs of producing petitioner’s nightclub/restaurant               






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