Maureen Monsour - Page 18

                                        - 18 -                                        

                             1989     Original    1991     1992      1993             
             Schedule E      Joint   1990 Joint   Joint    Joint     Joint            
             Relating to     Return   Return     Return    Return   Return            
            Monsour Gator   ($10,579)    –-        –-       –-        –-              
                Groves                                                                
            Laurel Valley   (81,380)  ($40,300) ($25,611) ($33,533) ($12,134)         
                Farms                                                                 
           Azure Tides, Inc.(210,727)   1–-     (7)  (58,156) (119,429)               
             Georgetown    2(119,748) (23,518)     –-       –-        –-              
             Square, Ltd.                                                             
           Georgetown Square(73)      (18)         –-       –-        –-              
             Assoc., Inc.                                                             
           Georgetown Square(7,245)      –-        –-       –-        –-              
             Assoc., Ltd.                                                             
               Scanner      111,221   259,254   93,398    72,451      –-              
             Corporation                                                              
               1The joint return did not show any amount because, as discussed below, 
          petitioner and Mr. Monsour did not receive Schedule K-1, Shareholder’s Share
          of Income, Credits, Deductions, Etc. (Schedule K-1), relating to Azure Tides,
          Inc., until after they filed the original 1990 joint return.                
               2Of the $119,748 total loss reported, $112,583 was reported as a passive
          loss and $7,165 was reported as a nonpassive loss.                          
               Petitioner did not examine in detail the 1989 joint return,            
          the original 1990 joint return, the 1991 joint return, the 1992             
          joint return, and the 1993 joint return before she signed each              
          such return.  Nonetheless, in signing each of those returns, she            
          was aware, inter alia, (1) that such returns claimed substantial            
          losses in Schedules C ranging from $24,275 to $187,336 and in               
          Schedules E ranging from $58,533 to $334,910, (2) that such                 
          claimed losses reduced income reported in such returns, and                 
          (3) that there were (a) no tax shown due in the 1989 joint return           
          or the 1991 joint return, (b) tax shown due of $34,713 in the               
          original 1990 joint return,5 (c) tax shown due of $1,255 in the             


               5As discussed above, when petitioner and Mr. Monsour filed             
          their original 1990 joint return, they did not pay the amount of            
          tax shown due in that return.                                               



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