Reginald Maurice Wise and Shannon Rae Wise - Page 16

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               2.   WRI's Interest Expense                                             
               Respondent contends that WRI may not deduct $100,138 of                 
          interest expense.  An accrual basis taxpayer may only deduct                 
          expenses or interest owed to a related cash basis taxpayer when              
          the amount involved is includable in the gross income of the cash            
          basis payee.  Sec. 267(a)(2).  WRI and Hersco are related                    
          taxpayers.  Sec. 267(b)(10); see sec. 267(e)(1).  WRI uses the               
          accrual method of accounting; Hersco uses the cash method of                 
          accounting.  As we concluded at par. A-1, above, the interest                
          payments on the Hersco mortgage are not includable in Hersco's               
          gross income.  Thus, the interest expense is not deductible on               
          WRI's fiscal year 1988 tax return.  Sec. 267(a)(2).  We agree                
          with respondent on this issue.                                               
               3.   Bona Fide Sale                                                     
               We need not decide whether the sale was bona fide.  For                 
          reasons discussed above at pars. A-1 and A-2, Hersco may not                 
          include the payments in income, and WRI cannot deduct the                    
          interest expense whether or not the sale was bona fide.                      
          B.   Wise's Management of WRI                                                
               1.   Management Fees                                                    
               Respondent contends that (a) WRI may not deduct management              
          and accounting fees of $173,974 for services performed by Pro-               
          Ser, and (b) Wise may not include $231,746 in gross income as                
          payment for those services.  Based on application of the factors             
          that we considered in deciding Hersco did not constructively                 




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