- 3 - Georgiou in 1990 can be recharacterized as a business interest expense under section 163(a); whether ownership of JAI stock was transferred from Georgiou to Kolonaki during 1989 or 1990, creating a dividend under section 304; and whether Georgiou is liable for penalties under section 6662 for 1989 and 1990. The issue remaining for decision as to Georgiou Retail Stores (GRS) is whether GRS's cost of goods sold in 1989 must be reduced by $130,181. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. The Georgious were residents of California, and Kolonaki and GRS had their principal places of business in California, at the time the petitions were filed. Kolonaki Georgiou incorporated Kolonaki in California in 1975 as a retail store that sold giftware and clothing from various parts of the world, predominantly merchandise from Greece. Prior to founding Kolonaki, Georgiou had obtained degrees in economics and mathematics and had worked as a systems analyst. Kolonaki was wholly owned by Georgiou from incorporation throughout the years in issue. From 1975 through 1987, Kolonaki expanded to include both wholesale and retail operations. By 1988, the retail division consisted of approximately 26 stores named "Georgiou". The "Georgiou" stores' merchandise consisted primarily ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011