- 4 - Education 1,461 Repairs 15,529 Supplies 235 23568,899 Total 77,084 79,632 Petitioner has substantiated $47,144, $51,007, and $38,661 of the expenses for the years 1986, 1987, and 1988, respectively. In addition, respondent has conceded that $7,767, $5,591, and $8,569 of the expenses are deductible on Schedule A of the 1986, 1987, and 1988 returns, respectively, subject to limitations (i.e., personal interest. Sec. 163(d)(6)(B)). Relationship Between Petitioner And Gilbert Petitioner and Dr. Alton L. Gilbert (Gilbert) met in 1968. They had a close personal relationship for many years, and a business relationship during many of those years. Gilbert and his wife were also members of petitioner's ministry for 20 years. Twenty-First Century Corporation (TFC) TFC was formed in 1979. Petitioner, Gilbert, and their wives owned the stock in TFC. Petitioner never contributed money or property to TFC, only services. TFC elected Subchapter S status from its inception. TFC's original business (to grow and sell pine trees) failed. Gilbert had some experience with computers so TFC entered the computer services business. TFC's computer business was sold to Technical Services, Inc., effective April 1, 1984. Technical Services, Inc. (TSI) TSI was incorporated on August 18, 1983. It elected subchapter S status effective January 1, 1984. TSI was also in the business of providing computer services. The principal shareholders of TSI were Gilbert and Mr. John Robbins (Robbins). Sale Of Assets From TFC To TSI In 1983 and 1984, TFC furnished computer services for TSI's clients. TFC and TSI attempted to form a joint venture called Systech Management toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011