- 9 - defendant to recoup some or all of the legal fees incurred, a judgment was entered against petitioner in the approximate amount of $70,000. By October 1, 1984, the Shaktoolik projects were substantially complete and operational, and INI had received payments totaling $1,875,000. The gross receipts reported on INI’s TYE 9/84 U.S. corporation income tax return amounted to $1,665,000. INI's TYE 9/84 return reflects taxable income of $87,177 after deductions. INI reported officer's compensation and wages on line 12 of the TYE 9/84 return in the amount of $165,000 and bonuses on line 26 in the amount of $63,800. The $165,000 shown on line 12 of INI’s TYE 9/84 return includes the deduction for $100,000 attributable to the accrual of the bonus payable to Burke’s estate. Shortly after Mutual Life denied the insurance claim, petitioner and Thorpe discussed the buy-sell agreement. During this discussion, petitioner told Thorpe he would pay $150,000 for the stock. Petitioner did not try to rescind the buy-sell agreement or reduce the purchase price of the stock; he simply tried to extend the time over which he had to pay. Later, during fall 1984, petitioner suggested to Thorpe that the estate could be paid faster, on the rationale that a layer of taxation could be eliminated, if the buy-sell agreement were reformed, nunc pro tunc, to reduce the purchase price by $100,000Page: 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