8
taxable year ending September 30, 1984. Petitioner signed Sugar
Valley's return for its taxable year ending September 30, 1984,
as its secretary. Carol Lockwood, an accountant with Fred A.
Lockwood & Co., prepared the DISC return for Sugar Valley's tax
year ending September 30, 1984. Carol Lockwood was one of the
accountants who handled the Stanko Packing account.
For its taxable year ending June 21, 1985, Stanko Packing
recognized taxable income in the following amounts from Sugar
Valley:
Gross receipts1 $2,457,890
Deemed distribution2 171,645
Accumulated DISC income3 253,322
1Stanko Packing received 90 percent, or $2,457,890, of
Sugar Valley's export receipts for products that it sold to
Sugar Valley from Oct. 1, 1983 to Sept. 30, 1984.
2Stanko Packing is deemed to have received a
distribution of $171,645, taxable as a dividend, from Sugar
Valley on Sept. 30, 1984. Sec. 995(b)(1).
3Stanko Packing is deemed to have received a
distribution of $253,322 of previously untaxed accumulated
income from Sugar Valley on Dec. 31, 1984. Sec. 995(b)(2);
sec. 1.995-4, Income Tax Regs.
2. Other Income and Deductions for 1985 Tax Year
Stanko Packing received other income of $128,776 in its 1985
taxable year. In 1985, Stanko Packing was entitled to deduct
$186,047 for trade or business expenses, $5,342 for property
taxes, $1,978 for interest, $51,250 for a worthless debt, and $85
for a charitable contribution.
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