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MEMORANDUM OPINION
WELLS, Judge: Respondent determined deficiencies in Federal
income taxes for petitioners Fleming G. Brooks and Sherry H.
Brooks in the case at docket No. 8981-03 as follows:
Addition to tax
Year Deficiency Sec. 6662(a)
1999 $207,552 $997.60
2000 190,105 1,027.60
Respondent determined deficiencies in Federal income taxes and
additions to tax for the Estate of Fleming S. Brooks and Merle R.
Brooks in the case at docket No. 8983-03 as follows:
Year Deficiency
1999 $157,207
2000 163,910
After concessions, the issue to be decided is whether the
advances of open account debt by petitioners to their closely
held S corporation in 1999 and 2000 provided petitioners with
basis to offset repayments of open account debt made by the
company in 1999 and 2000, prior to each respective advance.2
2All section references are to the Internal Revenue Code, as
amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011