- 5 - 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 asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011