- 17 - 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 thatPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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