Conrad Janis and Maria G. Janis - Page 17

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          the gallery’s basis in the collection should have been reported             
          in accordance with the discounted value that had been determined            
          by the Panel and agreed to by Conrad and Carroll for estate tax             
          purposes (i.e., $14,500,000) rather than the undiscounted value             
          (i.e., $36,636,630).  Consequently, adjustments were made to the            
          gallery’s reported COGS as follows:                                         
                     Year          COGS Per Return    COGS As Adjusted                
                     1990              $102,000            $40,369                    
                     1991             1,660,000          1,055,779                    
                     1992                45,000             17,180                    
                     1993               235,000             98,008                    
                     1994               727,500            287,929                    
                1/1/95-11/8/95        3,365,040          1,331,811                    
               11/9/95-12/31/95         395,000            156,333                    
                     1996               985,000            389,842                    
                     1997             1,277,000            505,410                    
          These adjustments to the gallery’s COGS caused a corresponding              
          adjustment to the gallery’s reported profits or losses for those            
          years.  Accordingly, respondent determined that the trust should            
          have reported that net operating losses totaling only $193,144              
          were distributed to Conrad and Carroll on its 1995 fiduciary                
          income tax return.  Respondent also determined that the                     
          partnership should have reported income rather than losses from             
          its operation of the gallery during 1996 and 1997.                          
               Based upon these adjustments, respondent determined that               
          adjustments to petitioners’ joint income tax returns for 1995,              
          1996, and 1997 were appropriate.  With respect to their joint               
          income tax returns for 1995, respondent determined that                     






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