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for decision relate to the tax treatment of payments which were
not made and income items which were not received, but which were
shown in the books and records of petitioners and these various
entities. The specific issues for decision are:
1. Whether Hersco may include in gross income for 1984
$189,014 of capital gain related to the sale of land to WRI, and
$100,115 of interest income from WRI related to a mortgage note.
We hold that it may not.
2. Whether WRI may deduct, for 1988, $100,138 of interest
related to a mortgage note it gave to Hersco and $173,174 for
professional services performed by Wise's sole proprietorship,
Pro-Ser. We hold that it may not.
3. Whether Wise may include in gross income $231,746 for
services Pro-Ser rendered to WRI. We hold that he may not.
4. Whether WRI may deduct $88,825 for services performed by
Wise. We hold that it may.
5. Whether WRI's payment of $38,500 to Wise was a non-
taxable repayment of a loan. We hold that it was not.
6. Whether $17,197 of expenses reported by Wise on Schedule
C of his tax return should be reported on Schedule A. We hold
that they should not.
7. Whether Hersco may deduct $73,122 of interest expense
related to loans Eicher made to Hersco. We hold that it may not.
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