Jack R. Prewitt and Shelley Prewitt - Page 12

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          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 $33,000             



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