James M. Rankin and Shirley Rankin - Page 7

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          his other expenses associated with bond forfeitures in 1988 from            
          sources other than the BUF accounts.                                        
               Petitioner does not have access to his BUF accounts until              
          the agreement is terminated and all outstanding bonds and all               
          other liabilities petitioner may have to Associated are                     
          satisfied.  Either petitioner or Associated may terminate the               
          agreement, with or without cause, subject to certain notice                 
          requirements.  Upon termination of the agreement and satisfaction           
          of all liabilities secured by the BUF accounts, the balance in              
          the BUF accounts is required to be released to petitioner.                  
               On his tax returns since 1968, petitioner offset his gross             
          receipts by the amount contributed to his BUF accounts as a                 
          portion of cost of goods sold.  However, the parties have                   
          stipulated that the offsets claimed by petitioner for payments to           
          the BUF accounts are not properly claimable in any taxable                  
          period.  Rather, if a forfeiture occurs and Associated is paid              
          out of a BUF account, the amount so paid is properly deductible             
          in the year payment is made.  Petitioner reported most, but not             
          all, of the interest accumulated on his BUF accounts on his                 
          Federal income tax returns for the taxable years 1968 through               
          1988.                                                                       
               Pursuant to the practice used by petitioner for accounting             
          for his BUF accounts from 1968 through 1988, petitioner did not             
          claim as deductions on petitioners’ tax returns forfeitures or              
          summary judgments paid from the BUF accounts maintained for him.            




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