- 5 -5
(c) Income (loss) from 223,264
* * * below
(d) Income not included 647
in column (c) plus
nontaxable income
(e) Losses not included (19,672)
in column (c), plus
unallowable deductions
(f) Withdrawals and (182,870)
distributions
(g) Capital account at end of ---
year (combine columns
(a) through (f))
The Schedule K-1 reflected that petitioner had a capital account
balance of zero at the end of 1990. Petitioner did not receive any
payments from Heidelberg & Woodliff with respect to the termination
of his interest in the law firm. Heidelberg & Woodliff continued
to exist following petitioner's departure.
Petitioner did not receive a Schedule K-1 for 1991. The only
distribution petitioner received in 1991 from Heidelberg & Woodliff
was from the firm's 401(k) plan.
Salary Reduction Plan Distribution
Petitioner participated in Heidelberg & Woodliff's 401(k)
salary reduction plan (the plan) which was administered by a firm
committee. The plan's funds were held in trust at Deposit Guaranty
National Bank (Deposit Guaranty).
In July 1989, petitioner borrowed $36,510.38 from the plan and
executed a promissory note to the plan. Later that month,
petitioner borrowed an additional $12,521.04 from the plan, for a
total of $49,031.42, and executed a new note to the plan. The note
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