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Respondent determined deficiencies in petitioners’ 1995,
1996, and 1997 Federal income taxes in the respective amounts of
$3,229, $4,414, and $8,721. The issue for decision for each year
is whether petitioners are entitled to a deduction for a net
operating loss carryover. The resolution of the issue depends
upon whether petitioners sustained a deductible loss in 1993 when
Jerome J. Klawitter (petitioner) surrendered his interest in a
certain partnership.
Background
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed a timely joint
Federal income tax return for each year in issue. At the time
the petition was filed, petitioners resided in Austin, Texas.
Petitioner holds a Ph.D. in engineering. Before the years
in issue he was a member of the faculty of several universities.
His doctoral dissertation, submitted in 1970, involved the
development of porous structures in ceramic materials to enable
biological attachment between the human skeletal system and an
orthopedic implant such as an artificial hip or knee. He taught
bioengineering at Clemson University until 1975, when he began
teaching courses in biomaterials and biomechanics at Tulane
University.
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