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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 included
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Last modified: May 25, 2011