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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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