Sam E. Scott - Page 5

                                        - 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         





Page:  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