6
Directors to "modify its prior determination and increase or
diminish the amount previously determined as cash requirements"
of petitioner.
Petitioner charges a maintenance fee to its tenant-
shareholders that varies according to the number of shares each
shareholder owns. Petitioner collects monthly apartment
maintenance payments from each tenant and a monthly parking space
rental fee from some of the tenants.
C. Petitioner's Income from Savings and Other Accounts
Petitioner earned interest income of $52,468 in 1989 and
$44,041 in 1990 from various savings and money market accounts,
and certificates of deposit with terms ranging from 2 months to 2
years. The parties stipulated that petitioner was not required
by law to have savings or money market accounts or certificates
of deposit.D. Characterization of Petitioner's Income
Petitioner's books and records did not distinguish between
patronage and nonpatronage sourced income. Petitioner did not
prepare records for 1989 and 1990 characterizing its current
earnings, liabilities, and net operating losses as patronage or
nonpatronage sourced.
Petitioner did not pay patronage dividends in the years at
issue. The parties stipulated that, because petitioner did not
pay patronage dividends, petitioner was not required to and did
not file information returns under section 6044. Petitioner
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