7
of Gymnastics. On that date, he also transferred to petitioner
his interest in (a) his and petitioner's home at 333 Skyline
Drive, Scottsbluff; (b) lot 2, block 5, Sunrise Hills Addition,
Scottsbluff; and (c) lots 1 and 2, block 2, Ditch North Addition,
Scottsbluff. Petitioner owned an interest in lot 2, block 5,
Sunrise Hills Addition, and in lots 1 and 2, block 2, Ditch North
Addition, before September 17, 1984. Stanko's interest in their
home at 333 Skyline Drive was worth from $10,000 to $12,500; his
interest in lot 2, block 5, Sunrise Hills Addition was worth
about $4,000; and his interest in lots 1 and 2, block 2, Ditch
North Addition was worth about $15,000 when Stanko transferred
them to petitioner.
On September 19, 1984, Stanko transferred the Packerland
note to petitioner. The transfer occurred in Nebraska.
Petitioner knew about the transfer within several days of
September 19, 1984. Petitioner did not pay Stanko Packing or
Stanko for the note. Petitioner paid the tax on the income from
the Packerland note. Stanko owed no debts to petitioner when he
transferred the note to her. Petitioner was married to Stanko at
that time.
D. Final Activities of Stanko Packing
1. Income From Sugar Valley Export Co.
Sugar Valley filed its tax returns as a DISC (Forms 1120-
DISC) for its taxable years ending September 30, 1983 and 1984.
Sugar Valley reported export receipts of $2,730,989 for its
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