Janice L. Morris - Page 22

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          certain funds that he had embezzled and that had not been re-               
          ported as gross receipts of Accu-Data or Meadows.                           
          Bad Debt and Legal Expenses                                                 
               Petitioner and Mr. Morris claimed deductions of $37,596 for            
          a business bad debt and $2,851.25 for legal expenses in Schedule            
          C of their 1987 joint return.  Those deductions completely offset           
          the $40,000 bonus that Mr. Morris had received during 1987 and              
          reported in that schedule.  The activity reported in Schedule C             
          of the 1987 joint return was identified as "financial services".            
               The business bad debt deduction claimed in Schedule C of the           
          joint return for 1987 was attributable to a loan (Galt loan) made           
          by Mr. Morris, who was not in the business of making loans during           
          that year, or by one of the entities that he controlled to either           
          Tom Galt (Mr. Galt) or Galt Communications, Inc. (Galt Communica-           
          tions).  Galt Communications, a corporation owned 80 percent by             
          Mr. Galt and 20 percent by Mr. Morris, was established for the              
          purpose of selling electronic appliances and cellular telephone             
          services.  At the time the Galt loan was made, Mr. Morris was not           
          an employee of Galt Communications, but he hoped to secure future           
          employment with it.                                                         
               The legal expenses claimed as a deduction in Schedule C of             
          the 1987 joint return were incurred during an unsuccessful                  
          attempt to recover the proceeds of the Galt loan.                           
               Petitioner inquired about the $37,596 business bad debt                
          deduction claimed in the 1987 joint return because she thought              




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