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refund due to petitioner in the amount of $215,353, which
respondent denied.
Also on October 15, 1996, petitioner filed an amended
individual Federal income tax return for 1993 on which petitioner
claimed a carryback of the balance of the 1995 claimed net
operating loss not used for 1992.4 Petitioner’s 1993 amended
income tax return reflected a refund due petitioner in the amount
of $368,263, which respondent paid.
None of Blackland’s income tax returns are in evidence.
Blackland did not claim bad debt deductions relating to the loans
Blackland made to the tenant farmers until the filing of
Blackland’s 1996 Federal income tax return, on which a bad debt
deduction in the total amount of $2,872,776 relating thereto was
claimed.
On audit of petitioner’s 1993 and 1995 individual Federal
income tax returns, respondent disallowed petitioner’s claimed
bad debt deduction for 1995 in the total amount of $3,207,568 and
the related net operating loss carryback and refund claimed for
1993.
4 Previously, in 1994, petitioner had filed an amended
individual Federal income tax return for 1993 to claim a foreign
currency transaction loss that petitioner had not claimed on his
original 1994 tax return.
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