6 Directors to "modify its prior determination and increase or diminish the amount previously determined as cash requirements" of petitioner. Petitioner charges a maintenance fee to its tenant- shareholders that varies according to the number of shares each shareholder owns. Petitioner collects monthly apartment maintenance payments from each tenant and a monthly parking space rental fee from some of the tenants. C. Petitioner's Income from Savings and Other Accounts Petitioner earned interest income of $52,468 in 1989 and $44,041 in 1990 from various savings and money market accounts, and certificates of deposit with terms ranging from 2 months to 2 years. The parties stipulated that petitioner was not required by law to have savings or money market accounts or certificates of deposit.D. Characterization of Petitioner's Income Petitioner's books and records did not distinguish between patronage and nonpatronage sourced income. Petitioner did not prepare records for 1989 and 1990 characterizing its current earnings, liabilities, and net operating losses as patronage or nonpatronage sourced. Petitioner did not pay patronage dividends in the years at issue. The parties stipulated that, because petitioner did not pay patronage dividends, petitioner was not required to and did not file information returns under section 6044. PetitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011