-12- Respondent determined that during 1989, the reported increases (debits) to the loan account totaled $537,683. The account was increased for such diverse items as cash withdrawals of $209,223 that were recorded as loans,5 Development's assumption of petitioner's $98,753 of indebtedness to Winterchase, and $39,038 of capitalized interest.6 Petitioner also recorded items that decreased the account (credits). Petitioner had credited the account for, among other items, $237,269 of cash that petitioner paid into the company, the reclassification of $116,395 of the loans as petitioner's salary, and petitioner's assumption of Development's indebtedness. Respondent disallowed $490,402 of these credit items, and allowed credits totaling $391,195, which respondent applied to reduce the beginning balance of the loan account, not to offset the increases recorded during 1989. Respondent determined that the alleged shareholder loans were not bona fide but actually were disguised distributions. Accordingly, respondent reduced the loan account balance for $39,038 of capitalized interest and increased petitioners' gross income for $307,976, the amount of the disguised distributions. 5 This amount includes political contributions of $1,500 that Development paid on petitioner's behalf. 6 Development charged petitioner interest on the alleged loans, and when petitioner did not pay the interest due, Development capitalized it by debiting the loan account for the unpaid amount.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011