-50- $983,104; the ending balance was $987,027. The total asset value was composed of the following assets, and their reported beginning and ending values: Cash, $886 and $439; other current assets, $414,701 and $11,374; loans to shareholders, $483,144 and $928,420; real estate loans, $70,511 and $46,794; and buildings and other depreciable assets, $13,847 and zero. The gross receipts and ending balances in the accounts in the fiscal years ending September 30, 1991 through 1995, are as follows: 1991 1992 1993 1994 1995 Gross Receipts -0- -0- -0- -0- -0- Other income 3$57,849 -0- 4$481 $165,073 4$1,515 Total assets $981,329 $977,744 $970,932 $945,531 $918,583 Cash $127 -0- -0- -0- -0- Other current assets 1 -0- -0- $1,683 -0- $5,302 Real estate loans -0- -0- -0- -0- -0- Other investments 2 -0- $23,718 $23,718 -0- -0- Loans to shareholder $981,202 $954,026 $945,531 $945,531 $913,281 Shareholder loan 99.99 97.57 97.38 100.00 99.42 account percentage 1 Asset account for tax refunds receivable. 2 The "other investments" account reflected petitioner's contribution of the one-half interest in the lot on Spalding Drive to INI that the corporation had earlier distributed to petitioners, and that had been recorded as a $23,718 increase to the loan account. Petitioner agreed to contribute this property to INI after a meeting with respondent's agent, Carolyn Hill, about a tax liability from a prior year in which Spalding and INI filed a consolidated return. Petitioner treated the contribution as a $23,718 loan payment. We have found that the earlier distribution of the property to petitioner was not a loan. Consistent with that finding, we hold that petitioner's return of the property to the corporation was a contribution to capital. The lot was sold in 1994 to pay the tax liability from thePage: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
Last modified: May 25, 2011