Peter J. Bresson - Page 6

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          Reporting Sale of Alhambra Property                                         
               On its U.S. Corporation Income Tax Return, Form 1120, for tax          
          year ended February 28, 1991, filed on March 5, 1993, Jaussaud              
          Enterprises reported a capital gain of $194,7053 from the sale of           
          the Alhambra property.  Jaussaud Enterprises also reported gross            
          receipts of $1,210, which resulted in a reported Federal income tax         
          liability of $49,683 for the tax year ended February 28, 1991,              
          which was not paid.  The return was signed by petitioner, as                
          corporate president.                                                        
               Petitioner did not report any gain from the sale of the                
          Alhambra property on his U.S. Individual Income Tax Return, Form            
          1040, for any year.                                                         
          Promissory Note                                                             
               At an undisclosed time following the sale of the Alhambra              
          property, petitioner sought professional advice with respect to the         
          tax consequences of Jaussaud Enterprises' transfer of the Alhambra          
          property to him and the subsequent sale of that property.  On July          
          15, 1993, petitioner, as president of Jaussaud Enterprises, called          
          a special meeting of the board of directors (which consisted solely         
          of himself) and determined that he owed the corporation $125,000.           
          (The record is void of any explanation as to how the amount of              
          petitioner's debt to Jaussaud Enterprises was determined to be              

               3    The gain on the sale of the Alhambra property was                 
          calculated as follows:  $329,000 (gross proceeds) + $28,130                 
          (depreciation previously allowed) - $162,425 (basis) = $194,705.            




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