- 15 - Pioneer and HSC, HSN made the following payments to Pioneer,7 and Pioneer included these amounts in its income: Calendar Year Amount 1985 $56,011.30 1986 700,645.57 1987 2,434,457.52 1988 2,453,928.21 1989 2,637,191.00 1990 3,136,668.00 1991 3,639,988.00 1992 3,441,262.00 Mr. Speer sold his HSN stock to Liberty Media Corp. (Liberty) in February 1993. After the sale, HSN discontinued making the 1- percent license payments to Pioneer. After engaging in various litigation, HSN agreed to pay Pioneer approximately $4,500,000 to terminate the License Agreement. Passive Activity Loss Issue During 1988, 1989, and 1990, Mr. Speer and Mr. Paxson owned 51 percent and 49 percent, respectively, of the stock of Gateway Marine, Inc. (Gateway). Gateway was an S corporation that operated a marine tug and barge business. Mr. Speer set up the corporation, hired its employees, handled finances, discussed the company’s bids, and purchased equipment for the company. Petitioners reported losses from Gateway of $24,882, $77,909, and 7We note that the 1-percent payment by HSN to HSC under the License Agreement terminated in early 1986, when HSC merged into HSN. HSN continued to pay Pioneer the 1-percent license fee.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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