Thwaites Terrace House Owners Corp. - Page 6

                                          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.  Petitioner                






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011