-7- WHEREAS, a dispute has arisen between the parties as to the amount of the taxpayers’ income, gains, losses, credits, and deductions related to investments and transactions with FoodSource, Inc.; and WHEREAS, the parties wish to determine with finality the taxpayers’ income, gains, losses [,] credits, and deductions for the taxable years [ending] December 31, 1979, December 31, 1980, December 31, 1982 and December 31, 1983 with respect to investments and transactions with FoodSource, Inc. NOW IT IS HEREBY DETERMINED and AGREED for Federal Income Tax purposes that: (1) No item of income, gain, loss, credit, and deduction from the taxpayers’ transactions and investments with respect to FoodSource, Inc. is recognized with regard to container #506622, which was considered to be placed in service December 5, 1983. (2) No depreciable basis shall be allowed for the container. (3) No investment tax credit shall be allowed for the container. (4) Any interest paid on the note financing the purchased container from FoodSource, Inc. would not be allowed as a deduction in any year. (5) No maintenance, insurance, or other operating expenses would be allowed to the extent cash payments were paid for them, unless a portion of the container income reported was used to offset the expense. (6) Overvaluation and negligence penalties are determined to be NONE and NONE for the year 1979, NONE and NONE for the year 1980, NONE and NONE for the year 1982, and $2,154.30 and NONE for the year 1983, respectively. (7) Any future receipt by the taxpayers of damages or monies from FoodSource or its related entities and agents shall be includedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011