- 12 - combination with the Mid-Continent corporations. Those corporations were intended to generate capital for the purchase of an insurance company, but evolved into shells for a Ponzi scheme. Petitioners have agreed that they failed to report $81,000 of income for 1983. Petitioners, however, contend that they are entitled to deduct expenses of the Mid-Continent corporations that were paid during and after the corporations ceased operation. To the extent those amounts were paid, payment was made with checks from petitioner's S corporation and petitioners seek to deduct the amounts on their individual 1983 income tax return. Finally, petitioners contend that they are entitled to a $90,000 deduction for their 1983 tax year in connection with the purchase and disposal of Riley. This amount has been characterized as a refund or repayment to the Mid-Continent corporations of the preincorporation payments petitioner had received during 1982. We address each of these matters separately. Payments of the Mid-Continent Corporations' Expenses-- Petitioner admits that he failed to report $81,000 ($60,000 plus $21,000) of income from the Mid-Continent corporations for 1983, but contends that he paid corporate expenses which more than offset the $81,000 of unreported income. No deduction for such expenses was reported or claimed on his 1983 return. First, it must be noted that the payments proven by petitioners total about $78,000. In that regard, about $33,000Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011