- 3 - Alexa Olson, A Minor, Kimberly Olson, Legal Conservator--docket No. 16945-95 Year Deficiency 1990 $3,195 Bruce A. and Kimberly A. Olson--docket No. 16946-95 Year Deficiency 1990 $55,679 Respondent conceded the accuracy-related penalty in docket No. 16787-95, and petitioner in docket No. 5220-95 has not argued, and thus conceded, the FSAA adjustment decreasing State Supply's sales promotion deduction for 1989. The sole issue for decision therefore is whether State Supply may amortize $2.5 million, or some lesser amount, for covenants not to compete. FINDINGS OF FACT State Supply was incorporated under the laws of the State of Oklahoma on October 14, 1963. At the time of the filing of its petition, State Supply's principal place of business was Tulsa, Oklahoma. During the taxable year 1989, State Supply was a corporation which elected to be taxed for Federal income tax purposes under the provisions of Subchapter S of the Internal Revenue Code of 1986, as amended. For the taxable year 1989, State Supply is controlled by the TEFRA notice and assessment procedures provided by sections 6241-6245. Douglas J. Von Allmen was the tax matters person for 1989. During the taxable year 1989, the shareholders of State Supply were Douglas J. and Linda L. Von Allmen, Bruce A. and Kimberly A. Olson, Charles B. andPage: 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