Spencer Medical Associates, Automotive Ventures, Inc. f/k/a Spencer Toyota, Inc., Tax Matters Partner - Page 3

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          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.                                                                       






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