- 4 - Farms. On the same date they received the notes, petitioners assigned the notes to their partnership, TMC Enterprises. TMC Enterprises was a general partnership in which petitioners were equal partners during the years in issue. On April 1, 1984, the debts owed by RAM Drilling and TMC Farms to TMC Enterprises were restructured as zero percent convertible subordinated debentures in the total amounts of $3,195,285 and $1,655,000, respectively. In the notices of deficiency, respondent determined, among other things, that petitioners were liable for additional taxes as a result of: (1) Imputed interest income on promissory notes from RAM Drilling and TMC Farms pursuant to section 482, and (2) the incorrect valuation of the RAM Drilling stock for purposes of the section 337 liquidation of TMC Resources. (This second issue was not in the notice of deficiency for 1979 and 1984 for Marcus R. Messman. Marcus R. Messman received two notices of deficiency.) Petitioners raised only these two issues in their petitions. The parties eventually settled the issue of the value of RAM Drilling stock for purposes of the section 337 liquidation of TMC Resources. On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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