J.J. Zand - Page 64

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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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