Allan & Judy N. Green - Page 3

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               During 1982, petitioners formed a second S corporation named           
          Gilliflower’s Shoppe Steinway Street, Ltd. (GF II).  In October             
          1982, GF II opened a 3,500-square-foot retail store in Astoria,             
          New York.  This store operated at a loss in 1982 and closed in              
          July 1984.  GF II later opened two other stores.  The record does           
          not establish the income or loss of GF II for any of its taxable            
          years.  Nor does the record establish the amount of the income or           
          loss of GF II that passed through to petitioners.                           
               On June 23, 1983, petitioners filed a chapter 11 petition in           
          the name of GF II in the United States Bankruptcy Court for the             
          Eastern District of New York.1  On the same date, they filed in             
          the same court a chapter 11 petition in their own names.  On                
          April 5, 1984, they filed in that court a chapter 11 petition in            
          the name of GF I.2  All three proceedings were converted to                 
          chapter 7 proceedings on November 16, 1984, and each of these               
          proceedings was closed in or about 1987.                                    
               Petitioners reported on their 1988 through 1997 Federal                
          income tax returns the following negative amounts of adjusted               
          gross income:                                                               




          1 At the time of this filing, petitioners each owned 50                     
          percent of the stock of GF II.  Also at that time, GF II reported           
          in its filings that its assets and liabilities on June 20, 1983,            
          totaled $722,850 and $448,640, respectively.                                
          2 At the time of this filing, petitioners were the sole                     
          shareholders of GF I.                                                       




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