-6- further concluded that the majority ($81,896) of the increase should be treated as loans, as should all balances existing prior to 1982. All issues arising from that examination (for both petitioners and Delivery) were ultimately settled by execution of two Forms 870-AD (one for petitioners individually and the second for Delivery) by petitioners and a representative of respondent’s Kansas City Appeals Office on June 1, 1990. Shortly after the settlement, petitioners’ accountant (Mr. Arthur) wrote off $527,428 against the corporation’s retained earnings. The $527,428 represented the balances in the following 12 accounts (which reflected withdrawals either by or for the benefit of petitioners): Title Amount Joe Schneller $ 70,125 Farm 163,694 S & S Oil 16,646 Jim Schneller 11,500 Cattle 34,967 Oil wells 3,700 Barnard Realty 46,031 Transportation management 5,585 Payable to Marilyn Schneller (23,856) Insulating coating 54,656 BG Beer 8,200 Investment-BG Beer 136,180 TOTAL $527,428 Respondent does not challenge $51,065 of the $527,428 written off. Respondent does, however, challenge $476,363 of the writeoff on the grounds that the 12 accounts had consistently been carried on the corporate books as loans, and petitioners never included any part of the $476,363 in their personal income. Petitioners were solventPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011