- 5 - Corporation 1989 1990 1991 FGE $243,682 $291,930 $10,615 TTI 152,838 16,259 -- BEL -- -- 40,503 Total $396,520 $308,189 $51,118 Petitioners do not dispute respondent's determination that these expenses were improperly deducted by the corporations or that the amounts are taxable income to them. Most, but not all, of the above expenses for FGI and TTI related to Mr. Garrett's personally owned muscle cars. Additionally, the expenses disallowed to BEL were checks that were written by or for Mr. Garrett. Muscle Cars 1. 1989 Sale Prior to 1989, Mr. Garrett collected muscle cars as a hobby. In January 1989, Mr. Garrett sold 25 automobiles from his muscle car collection for $1.2 million.3 On their Federal income tax return for 1989, petitioners claimed a basis of $800,000 in the muscle cars sold. In the notice of deficiency, respondent determined that petitioners failed to demonstrate that they were entitled to any basis in the capital assets sold and, therefore, realized a gain of $1.2 million from the sale of the muscle cars. 3After this sale, Mr. Garrett had 10 muscle cars remaining from his original collection.Page: 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