- 149 - of CDC. As of March 31, 1980, the McZand note payable to McCabe in the amount of $772,827.69 had been assigned to petitioner. Furthermore, as of the March 31, 1980, trial balance the value of McZand's common stock, all of which was owned by petitioner, constituted the sole contribution of $500 to McZand's capital. The claimed debt from McZand Corporation to petitioner and his children was a capital contribution rather than a loan. The Stoneridge, Westgrove, and Pickerington properties were distributed to petitioner for no consideration. As of December 1979 petitioner's disposition of the Stoneridge, Westgrove, and Pickerington properties would have produced $657,000 of short- term gain. Petitioner's claimed deduction for the transfer of property to Kenyon College is reduced by $657,000; i.e., the amount of ordinary income or short-term capital gain that would have been recognized had petitioner sold the property. X. Claimed Losses From Trusts, Partnerships, Subchapter S Corporation, and Farming Operations On his 1976 tax return petitioner claimed a loss of $1,518 for the Yanson Trust which respondent disallowed. There is no evidence in the record showing that any loss was incurred in 1976 or the amount thereof. Therefore, petitioner is not entitled to a 1976 loss of $1,518 from the Yanson Trust.Page: Previous 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 Next
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