- 3 - dollars ($400,000) when the contract was executed. The balance of the stated consideration was reflected in a Cr$2,514,400,000 promissory note from Spencer Medical to Coral (the Coral note), the equivalent (in 1983) of US$2.8 million. The Coral note was payable in Brazilian cruzeiros in four equal payments on December 1 of each of the years 1990, 1991, 1992, and 1993. Each payment was to consist of one-fourth of the original Coral note principal (Cr$628,600,000) and all accrued interest as of the date of the payment. At the time the Coral note was executed, the principal payment due on December 1, 1990, was the equivalent of US$700,000. Spencer Medical's Federal income tax return for the calendar year ended December 31, 1983, was timely filed with the Internal Revenue Service Center in Philadelphia, Pennsylvania. On its 1983 return, Spencer Medical claimed a research expense deduction in the amount of $3.2 million. The return did not disclose that the research expense arose out of a promissory note or out of a transaction with Coral. Spencer Medical's 1983 return was not examined by the Internal Revenue Service (IRS) prior to April 15, 1987. Spencer Medical's Federal income tax return for the calendar year ended December 31, 1990, was filed with the Internal Revenue Service Center in Philadelphia, Pennsylvania, on October 21, 1991.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011