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1989 13,742.45 Constitutional challenge
action
2,239.85 Dial One Mobile
The Dial One Mobile work listed above was billed by W&C to Rhys,
not to NITCO. Petitioners concede that the $2,239.85 is not
deductible by NITCO and represents constructive dividend income
to Mr. Mussman.
During 1989, NITCO made certain legal expenditures totaling
$88,484, for which it claimed no deduction. A portion of these
expenditures in the amount of $75,342 was recorded by NITCO in an
account called "Cellular Telephone Investment". The remaining
$13,052 of the expenditures was recorded by NITCO in an account
called "Other Investments". The $88,484 in legal expenditures
was attributable to the following matters:
Payee Amount Matter
Andrew & Kurth $1,166.59 Dial One Mobile
B&H 32,363.64 Dial One Mobile
EMCI 3,327.50 Purchase of cellular
telephone publications
Handlon & Handlon 1,525.81 Work for Dial One USA and
Intelcom
132.00 Work for FiberComm
229.00 Unknown
234.00 Incorporation of
Northwestern
Indiana Cellular
LMN&G 2,982.58 Work for Rhys
2,564.05 Indiana RSA #1 venture
4,400.00 Conceded by petitioners to
be constructive dividend
to Mr. Mussman
Unknown 39,968.83 Unknown
On the record presented in the instant cases, it is not clear
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