- 7 -7
etc.) was issued to petitioner for 1991 reporting a taxable
distribution of $85,455.49. The address on the Form 1099 was the
same as that on petitioner's notice of termination submitted by
Heidelberg & Woodliff to Deposit Guaranty. At no time did Deposit
Guaranty personally notify petitioner that his loan was charged off
or that the bank deemed the loan repaid.
1991 Federal Tax Return
On his 1991 Federal tax return, petitioner reported adjusted
gross income of $69,424. On his Schedule E (Supplemental Income
and Loss) under income or loss from partnerships and S
corporations, petitioner reported a $121,500 loss from Heidelberg
& Woodliff. Petitioner calculated the loss based on his 8.86-
percent interest in the firm's accounts receivable, work in
progress, cash on hand, and furniture and equipment that he never
received upon his departure from the firm.
Petitioner also reported $40,100 in taxable individual
retirement account distributions.1 On his Schedule A, petitioner
claimed $33,943 in investment interest expense deductions.
In April 1992, petitioner filed Form 4868 (Application for
Automatic Extension of Time To File U.S. Individual Income Tax
Return) requesting an automatic 4-month extension of the time to
file his 1991 tax return. Petitioner estimated his total 1991 tax
1 The distributions were actually from the Heidelberg &
Woodliff 401(k) salary reduction plan, not from any individual
retirement accounts.
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Last modified: May 25, 2011