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deductions: (1) $49,817 for the 1994 Caroline County farm
expenses, (2) $29,202 for the 1994 Virginia Beach property
expenses, (3) $17,807 for the legal fees with respect to the
Mitchums Creek property, (4) $7,762 for the 1994 child care
expenses, and (5) $10,909 for depreciation with respect to the
Virginia Beach property (1994 Virginia Beach property deprecia-
tion deduction). In Delaware Corporation’s 1994 return, Delaware
Corporation reported $7,200 as gross rent received with respect
to the Virginia Beach property (1994 claimed rent of $7,200).
Delaware Corporation filed Form 1120 for its taxable year
1995 (Delaware Corporation’s 1995 return).7 In Delaware Corpora-
tion’s 1995 return, Delaware Corporation claimed the following
deductions: (1) $23,654 for the 1995 Virginia Beach property
expenses, (2) $3,321 for the 1995 child care expenses, and
(3) $5,454 for depreciation with respect to the Virginia Beach
property (1995 Virginia Beach property depreciation deduction).
In Delaware Corporation’s 1995 return, Delaware Corporation
claimed an NOL.8 Delaware Corporation carried part of that NOL
back to its taxable years 1993 and 1994 and, as discussed below,
7Delaware Corporation’s 1995 return is not part of the
record in this case. We are unable to determine from that record
whether a preparer prepared Delaware Corporation’s 1995 return
and, if so, the identity of such preparer.
8The record does not disclose the amount of the NOL that
Delaware Corporation claimed in Delaware Corporation’s 1995
return.
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