- 13 - A certified public accountant (C.P.A.) prepared petitioner’s 1986 income tax return on April 21, 1987. In it, petitioner reported no gross income and no tax due. On November 5, 1987, petitioner’s C.P.A. prepared petitioner’s amended return for 1986. In that return, petitioner claimed a $9,339,066 loss on Form 4797, Gains and Losses From Sales or Exchanges of Assets Used in a Trade or Business and Involuntary Conversions. The $9,339,066 loss was based on petitioner’s share of the family assets expropriated by the Iranian government. Petitioner attached the following statement to his amended 1986 return: The losses taken on Form 4797 represent taxpayers’ losses of business assets in Iran. They are based solely on the Census of Claims by United States Persons Against Iran filed with the Office of Foreign Assets Control, Department of the Treasury, Washington, D.C. 20220, by the taxpayers’ family. The taxpayers’ family has allocated to each family member their proportionate interest in such assets. The only losses taken were those the taxpayer deemed to be business assets and it is their contention that amount claimed are their costs. The taxpayers determined that these assets were only seized in 1986. The tax preparers have not verified the assets, their costs or the year the loss was incurred. E. Petitioner’s 1987-91 Income Tax Returns Petitioner filed returns for 1987-89, and petitioners filed joint returns for 1990-91 in which they reported the following:Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011