- 8 - had $800,000 of unrecorded liabilities which should have been offset against the S corporation's earnings and profits. Respondent did not reduce the earnings and profits by any portion of the unrecorded liabilities in the notice of deficiency determination. Petitioners filed their 1988 joint Federal income tax return after October 31, 1989, and they had not requested an extension of time in which to file their return. Petitioners conceded the following adjustments: Resthaven's travel and entertainment expenses of $14,937, $14,828, and $47,928 for 1987, 1988, and 1989, respectively; a $15,400 reduction in Resthaven's cost of goods sold; Resthaven's equipment lease expense of $1,183, $8,882, and $8,076 for 1987, 1988, and 1989, respectively; Resthaven's vehicle insurance expense of $412, $933, and $1,805 for 1987, 1988, and 1989, respectively; disallowed medical expense for 1987; and an adjustment to miscellaneous itemized deductions for 1987. OPINION Bad Debt Resthaven lent petitioner's friend, Mr. Kamas, $110,000 in December 1986. Petitioner caused his corporation to lend Kamas $110,000 so that Kamas could participate in the building of aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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