Alton W. Burns and Pamela Burns - Page 5

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            had was materials in the molds."  Petitioners did not have the                               
            assets, including the boat molds, appraised or valued at the time                            
            of the exchange.  However, on Riviera's Form 1120, U.S.                                      
            Corporation Income Tax Return, for the year ending September 30,                             
            1980, Riviera's assets were valued at $135,731.                                              
                  Petitioners claim that Riviera was liquidated on October 31,                           
            1979, the date they retained the collateral.  The parties have                               
            stipulated that Riviera conducted no business from approximately                             
            September 30, 1980 to September 30, 1990.  However, Federal                                  
            corporate income tax returns continued to be filed for Riviera up                            
            until the year ending September 30, 1990.  For the years ending                              
            September 30, 1980, September 30, 1981, September 30, 1982,                                  
            September 30, 1983, and September 30, 1984, Riviera continued to                             
            claim depreciation deductions for office equipment on the                                    
            corporate tax returns.  Petitioner husband claimed the corporate                             
            tax returns continued to be filed for the following reason:                                  
                  We didn't file in each year, Your Honor.  My attention                                 
                  was -- as we were shut down and that was the end of it,                                
                  and then we didn't file any income tax returns after we                                
                  shut down.                                                                             
                        And then IRS wrote us a letter, so we went ahead                                 
                  and the accountant took the last return and filed it                                   
                  and sent them in.  And at that time we thought maybe                                   
                  things could turn around and we could maybe start back                                 
                  up, which never happened.  Things were improving, but                                  
                  it still didn't work out that way.                                                     
                  Riviera's Federal corporate income tax return for the year                             
            ending September 30, 1980, reflects the sum of $78,541 as                                    
            shareholder loans from petitioners to Riviera, and $30,000 as                                





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