- 15 - Year COGS Ordinary Loss 1996 $985,000 $512,916 1997 1,277,000 546,466 The Schedules K-1 (Form 1065), Partner’s Share of Income, Credits, Deductions, etc., attached to the partnership’s Forms 1065 for 1996 and 1997 indicate that the partnership’s ordinary losses were distributed equally between Conrad and Carroll. Petitioners’ Income Tax Returns for 1995, 1996, and 1997 Dean A. Avedon, C.P.A., prepared Conrad and Maria’s joint income tax returns for 1995, 1996, and 1997. Silverman prepared the Schedules K-1 (Form 1065) that were attached to those returns. On each of those joint income tax returns, Conrad and Maria reported that they had no taxable income and owed no income tax. On their joint income tax return for 1995, Conrad and Maria reported the net operating loss carryover of $1,750,480 that had been distributed to them from the trust. The following explanation was given on this Form 8275 for the existence of the claimed net operating loss carryover: Value of paintings of an art gallery (Sidney Janis Gallery) transferred to a trust were valued at $36636630 by the IRS at the decedent’s (Sidney Janis) death. After a blockage discount allowed by the IRS on audit the estate paid inheritance tax on an amount of $14500000 after the blockage discout [sic] reported on Form 706. In accordance with the decision in Elizabeth G. Augustus, 40 BTA 1201, 12/10/31 (ACQ) the trust used the individual value of the paintings prior to the blockage discount for the paintings sold by trust and for the one (1) painting sold by the heirs as reported on Schedule C.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011