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For 1987, petitioners filed a return that reflected a
partnership loss of $4,226 and a farming loss of $45,030,
resulting in zero regular tax liability but an alternative
minimum tax liability of $462. Petitioners filed with their 1987
return a Form 3800, General Business Credit, on which they
claimed a “tentative general business credit” of $21,765.
Although the record is not clear, it appears that the source of
this credit was a carryforward from the 1986 taxable year.
Because petitioners reported zero regular tax liability in 1987,
none of this claimed credit was used by petitioners to offset any
tax liability for 1987.
After filing their 1987 return, petitioners filed a Form
1045, Application for Tentative Refund, on which they requested
refunds with respect to their 1984, 1985, and 1986 taxable years,
based on the carryback of the unused general business credit
claimed on the 1987 return. On this form, petitioners reported
the following adjusted total tax liabilities:
1984 1985 1986
Income tax $7,586 $7,401 $8,483
General business credit (7,586) (7,326) (7,479)
Other credits -0- (75) -0-
Regular tax liability -0- -0- 1,004
Alternative minimum tax liability 142 484 1,491
Total tax liability 142 484 2,495
For 1988, petitioners filed a return that reflected a
farming loss of $39,443, resulting in zero tax liability.
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Last modified: May 25, 2011