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carried the balance (i.e., $74,021) forward to its taxable year
1997.
Delaware Corporation filed Form 1120 for its taxable year
1997 (Delaware Corporation’s 1997 return). Failes & Associates,
P.C., was the preparer of that return. In Delaware Corporation’s
1997 return, Delaware Corporation claimed an NOL deduction of
$74,021 that was attributable to a claimed NOL carryforward from
1995.
Ms. Havens’s Returns
Ms. Havens filed Form 1040, U.S. Individual Income Tax
Return (Form 1040), for her taxable year 1994 (Ms. Havens’s 1994
return). Braun, Dehnert, Clarke & Co., PC, was the preparer of
that return. In Ms. Havens’s 1994 return, Ms. Havens did not
report as income the following payments that Delaware Corporation
made during 1994: (1) $49,817 for the 1994 Caroline County farm
expenses and (2) $29,202 for the 1994 Virginia Beach property
expenses. In Ms. Havens’s 1994 return, Ms. Havens did not report
as income Delaware Corporation’s assignment in 1994 of its
interest in the Caroline County farm contract to MSG-STG L.P., a
family limited partnership controlled by Ms. Havens.
Ms. Havens filed Form 1040 for her taxable year 1995 (Ms.
Havens’s 1995 return). “KROBOTHs” was the preparer of that
return. In Ms. Havens’s 1995 return, Ms. Havens did not report
as income $23,654 for the 1995 Virginia Beach property expenses
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