- 10 - Sometime after respondent's agent brought the above- omitted amounts and certain disallowed deductions to Mr. Cordes' attention during the audit, petitioner filed Form 1120X, Amended U.S. Corporation Income Tax Return, with the Internal Revenue Service Center, Austin, Texas. On that return, petitioner reported additional gross receipts in the aggregate amount of $425,955, composed of the following items: Deposits to account No. 312 $179,005.00 Late charges & collection fees 56,712.00 Bankruptcy collections 15,745.15 American Express payments 168,854.36 Martin's Restaurant payments 5,638.94 Total 425,955.45 The above items designated as payments to American Express and Martin's Restaurant are payments for personal expenses of Edmund J. Cordes and his family that were deducted on petitioner's 1990 return as "Repossession Costs". Petitioner's amended return for 1990 claims a loss in the amount of $336,912 to offset the additional income reported on the return, and it makes reference to an adding machine tape to explain the nature of the loss. In substance, the adding machine tape states as follows: Cordes Finance Corp. 12-31-90Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011