-11- $11,374, and his indebtedness to INI was increased by that same amount. When Carlsgate went out of business in 1991, petitioners each reported one-half of the remaining loan balance, $5,131 (total $10,262), as long-term capital gain income from the exchange of their stock. Through a series of similar assumptions and transfers executed by journal entries, on December 31, 1991, petitioner was indebted to INI, his sole remaining corporation, for $980,527. Issue 1. Whether Petitioner's Withdrawals From Development in 1989, 1990, and 1991 Were Taxable Distributions Respondent determined that Development made distributions to petitioner that exceeded his stock basis by $298,622, $261,591, and $224,827 for 1989, 1990, and 1991, respectively. In addition, respondent determined that in 1989 petitioner received $8,854 of dividends that Development distributed from its C corporation accumulated earnings and profits. Petitioner asserts that with respect to all of the years at issue, the withdrawals were loans that Development made to him. 1989 On January 1, 1989, Development had $8,854 of accumulated earnings and profits on its books and records that it earned when it was a C corporation. According to the loan summary prepared by petitioner's accountants, the 1989 beginning balance in Development's loans to shareholder account was $427,368.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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