Harry D. Bledsoe and Annie L. Bledsoe - Page 8

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            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 a                               








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