Fawzi and Dolores Tay Tay Assaad - Page 7

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          Profit or Loss From Business (Sole Proprietorship), to their                
          joint return for 1992 reporting a loss of $1,890,682 for Mr.                
          Assaad’s real estate development business.  Petitioners reported            
          gross receipts of $2,675,272, cost of goods sold of $2,226,664,             
          and a gross profit of $448,608 for that business.  Petitioners              
          claimed expenses of $2,339,290 (separate from, and in addition              
          to, the cost of goods sold).  Petitioners did not report                    
          sufficient income on their 1992 Form 1040, U.S. Individual Income           
          Tax Return, from which to deduct the entire loss.  They carried             
          forward the loss to their 1993, 1994, 1995, 1996, and 1997                  
          taxable years.  On petitioners’ 1996 and 1997 Forms 1040, they              
          claimed net operating loss (NOL) carryforward deductions which              
          reduced their taxable income to zero for those taxable years.               
               In computing the gross receipts from the development                   
          business for 1992, petitioners did not report any of the proceeds           
          from the foreclosure sale of 15 Isabella on the 1992 return.  The           
          gross receipts from that sale in 1992 were at least $2,052,385.             
               For many years, Roy Hunt prepared petitioners’ tax returns,            
          and he was their accountant.  At some point, Anthony Lopez took             
          over Mr. Hunt’s practice, and he became petitioners’ tax return             
          preparer and accountant about a year before Mr. Hunt’s death.               
          Mr. Lopez could not recall whether he prepared petitioners’ 1992            









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