- 24 -
Accu-Data--Constructive Distribution
Accu-Data, a corporation wholly owned by Mr. Morris during
all relevant periods, was a stockholder in Technical Programs,
Inc. (TPI). During 1981, Accu-Data transferred $12,000 to TPI.
During 1982, Accu-Data transferred an additional $300 to TPI.
Between 1981 and 1983, TPI made payments to and on behalf of
Accu-Data that totaled at least $5,045. TPI was dissolved on
February 1, 1986, because of its failure to pay franchise tax to
the State of Illinois.
The Form 1120S that Accu-Data filed for its short taxable
year July 1 through December 31, 1988, reflected as an asset on
its balance sheet at the beginning of the year "Loans to
shareholders" (stockholder loan account) in the amount of $7,217.
No amount was reflected on the balance sheet at the end of that
year concerning those purported loans. The balance sheet in the
Form 1120S that Accu-Data filed for 1989 showed no assets and
liabilities as of the beginning and end of that year. The Form
1120-A that Accu-Data filed for its taxable year ended June 30,
1987, contained a balance sheet that showed that the stockholder
loan account increased from $4,394 to $7,217 during that year.
The Form 1120-A that Accu-Data filed for its taxable year ended
June 30, 1988, contained a balance sheet that showed a balance of
$7,217 in the stockholder loan account at the beginning and end
of that year.
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011