- 13 - when the properties were foreclosed upon. For example, in 1989, petitioners reported adjusted gross income of zero. In 1990, petitioners reported adjusted gross income of -$820,198. Petitioners contend that losses from foreclosures on the five properties created the net operating losses. Based on the stipulated facts in this case, however, four of the properties were foreclosed upon between 1982 and 1985, and the fifth property was not foreclosed upon until 1992. This is one of the many inconsistencies evident in petitioners’ case. Petitioners have failed to offer credible testimony to meet their burden of substantiation in this case. 3. Petitioners Provided No Financial Records Petitioners failed to provide any financial documentation to substantiate the net operating losses. Petitioners did not produce books or records for the alleged loss years to substantiate the claimed losses. Petitioners provided no financial statements from the H & H partnership. Petitioner conceded that he does not have any records for the properties or the H & H partnership, as his partner Mr. Hornbeak retained all the records. Petitioner failed to obtain these records from Mr. Hornbeak. Petitioners provided no financial statements from H & H Land Development Corp. Petitioners provided no receipts as to losses on the property. Petitioners provided no information asPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011