- 11 - Transaction Date1 Amount Reference May 5, 1988 $43,092.89 Write off Loss in CPI July 31, 1988 10,000.00 Loss in CPI/Re: Mgt. Fee Aug. 31, 1988 10,000.00 Loss in CPI/Re: Mgt. Fee Sept. 30, 1988 10,000.00 Loss in CPI/Re: Mgt. Fee Oct. 31, 1988 10,000.00 Record loss from CPI Rec Nov. 30, 1988 10,000.00 Loss from Uncollect Rec Dec. 31, 1988 10,000.00 Loss Uncollect Rec-CPI 1The "transaction date" indicates the dates on which these items were written off in Weeden's books rather than the dates on which the cash was transferred. In this manner, Weeden wrote off the balance in the account labeled RECEIVABLE FROM CPI. On its Form 1120, U.S. Corporation Income Tax Return for 1988, Weeden claimed a bad debt deduction in the amount of $103,093, the amount it had advanced for the CPI project. Beginning in September 1989, respondent examined WAI's returns for 1987, 1988, and 1989. During the examination, WAI's representatives raised the issue whether WAI had erred by including in WAI's gross income for 1987 the advances that had been made by Weeden during the year. WAI's representatives took the position that the advances constituted either equity investments in WAI or loans to WAI which, in either event, should not have been included in petitioners' gross income in 1987. A letter dated September 18, 1991, from Mr. Flaherty and addressed to Mr. Whelpley at WAI, states that Weeden considered the subject advances as loans to WAI, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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