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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.
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