Larry J. and Angela L. Siggelkow - Page 2
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US Tax Court > 1999 > Larry J. and Angela L. Siggelkow - Page 2
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the ordinary course of Mr. Siggelkow’s business, he made a bona
fide loan to a company he partially owned that became a worthless
business debt in 1992 when the company went out of business.
Respondent disputes that the advance of funds was made in the
course of petitioner's trade or business.
FINDINGS OF FACT
The stipulation of facts and the exhibits attached thereto
are incorporated herein by this reference.
Petitioners Larry and Angela Siggelkow, husband and wife,
resided in Las Vegas, Nevada, at the time their petition was
filed. Angela Siggelkow is a petitioner in this case because she
joined in filing returns with Larry Siggelkow. Subsequent
references to “petitioner” refer only to Larry Siggelkow.
During the tax year in question, petitioner owned one-third
of the stock in PLG Enterprises, Inc., d.b.a. Eagle Jet Charter,
Inc. (PLG), and all of the stock in Lang Aire, Inc. (Lang), as
well as interests in other aviation-related companies.
In May 1992, petitioner borrowed $255,000 from Clark County
Credit Union (CCCU) against funds held in his personal accounts
at CCCU. The CCCU loan agreement specified a 5.75-percent
interest rate with a single balloon payment due in June 1993.
Petitioner instructed the credit union to wire the funds directly
to AIG Aviation Insurance Services, Inc. (AIG), on behalf of PLG
as payment for its successful bid to buy a salvaged Lear jet held
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