6
1985, and 1986. Loans from shareholders of $925,049 were
reported on the 1987 corporate return. No loans from
shareholders were reported on the 1988 and 1989 corporate
returns.
Bob Wade Ford never made a profit. Bob Wade Ford reported
losses on its Forms 1120S (S corporation tax returns) and
Schedule K-1 losses allocated to petitioner and Wade from 1976 to
1989 as follows:
Losses per K-1 losses were allocated to:
Year tax return Petitioner Wade
1976 ($114,476) ($91,581) --
1977 (118,690) (90,204)
1978 (191,025) (145,179)
1979 (734,701) (587,761) ($146,940)
1980 (474,239) (379,391) (94,848)
1981 (347,016) (312,315) (34,701)
1982 (467,196) (420,476) (46,720)
1983 (159,044) (143,140) (15,904)
1984 (942,985) (942,985) --
1985 (642,216) (642,216) --
1986 (322,096) (322,096) --
1987 (122,976) (122,976) --
1988 (256,752) (256,752) --
1989 (133,709) (133,709) --
Total (5,027,121) (4,590,781)
Losses were allocated between petitioner and Wade on the
basis of the following ownership ratios:
Years Petitioner Wade
1976-81 80% 20%
1982-83 90 10
1984-89 100 0
Gary Kane (Kane), a certified public accountant (C.P.A.) for
24 years, prepared tax returns for Bob Wade Ford beginning in
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