- 46 - 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/restaurantPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
Last modified: May 25, 2011