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Negative Amounts of
Taxable Year Adjusted Gross Income
1988 $662,246
1989 601,726
1990 545,994
1991 518,707
1992 468,723
1993 443,339
1994 497,225
1995 617,510
1996 682,840
1997 738,081
Included in these amounts were wages of $117,412, $137,272,
$140,435, $130,440, $154,509, $122,322, $110,766, $125,600,
$138,291, and $84,233, respectively. The record does not
establish the amounts that petitioners reported as their taxable
income for any of the years 1988 through 1997. Nor does the
record establish petitioners’ income (either adjusted gross or
taxable) for years before 1988.
For the subject years, petitioners filed with the
Commissioner Federal income tax returns using the filing status
of “Married filing joint return”. They claimed on those
respective returns deductions for NOL carryovers of $832,503 and
$719,564. Neither the 1998 nor the 1999 return details the
composition of the NOL carryovers, e.g., the amounts of the
purported NOLs included within the reported NOL carryovers or the
years in which those NOLs purportedly arose. Petitioners
ascertained their NOL carryover from each year after 1980 by
deducting in full any NOL carryover to that year and treating the
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Last modified: May 25, 2011