- 12 -
Petitioner reported on his Federal income tax returns the
following amounts of income:
Years Salary
1985 $318,172
1986 202,612
1987 1516,233
1988 180,000
1989 152,400
1990 2127,700
1991 127,000
1992 104,000
1993 104,000
1994 156,000
1This figure has been rounded off to the nearest dollar. In
that year, petitioner obtained a salary of $280,000, and received
a bonus of $236,000. The bonus went back to petitioner's auto
dealership to pay off the $150,000 note and a $80,000 loan he
received from the dealership.
2Petitioner received $45,200 prior to the loss of his auto
dealership.
As a dealer/owner, petitioner received a total of $893,833 in
income from the auto dealership while it was in business.
Petitioner, on Schedule D of his 1990 Federal income tax
return, claimed $350,000 in capital losses under section 1244 and
an additional, unspecified, $50,000 loss. In addition, the
$400,000 paid to Sanwa Bank from the foreclosure proceeds was
claimed as a loss on petitioner's Schedule C as "personal
guarante [sic] of loan from corporation".
After the termination of petitioner's auto dealership, he
worked almost 6 months as the manager of a Ford dealership in
Orange County, California. Thereafter, Acura requested
petitioner to assist a Huntington Beach, California, dealer.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011