Carl Goudas and Marilyn Goudas - Page 23

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          were included in the reported amount realized of $4.8 million,              
          and then distributed to petitioner.  On the Coastal side of the             
          transaction, there's a disparity in the book and tax treatments             
          of petitioner's participation in Coastal:  Coastal recorded on              
          its books a contribution to capital by petitioner in the amount             
          of $700,000; on Coastal's tax balance sheet reconciliation of               
          partners' capital accounts, petitioner is shown as having made no           
          capital contribution.  This disparity is reflected in Coastal's             
          book and tax accounting for the receipt of the Mall, which was              
          booked at a value that exceeds its tax basis by approximately the           
          same amount as the equivalent amounts of the credits and                    
          petitioner's capital contribution.                                          
               It's the tax treatment of the credits, at both the Pecaris             
          partnership and partner levels, over which the parties part                 
          company.                                                                    
               A.  Amount of Pecaris Gain                                             
               1(a)  Amount Realized                                                  
               Having opened up the transaction for review, we must first             
          determine the amount of the Pecaris gain on its sale of the Mall            
          to Coastal.  Under section 1001(a) "The gain from the sale or               
          other disposition of property shall be the excess of the amount             
          realized therefrom over the adjusted basis" of the property.                
          Under section 1001(b), "The amount realized * * * shall be the              







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Last modified: May 25, 2011