- 13 - accept that premise arguendo, petitioners bear the burden of proving that the method they used to compute the amount realized was reasonable in light of the facts and circumstances. S. Gaudiano testified that he computed the amount realized of $145,430 on Four A's amended Form 1120S using two different methods: (1) A balloon payment calculation using a normal banking rate of 11-1/4 percent and (2) a junk bond calculation using a 24- to 25-percent discount rate. S. Gaudiano testified that the two methods reached similar results. Neither Four A nor petitioners showed the present value calculations on their amended returns, and during his testimony S. Gaudiano failed to explain to the Court how either of his two alleged methods arrived at an amount realized of $145,430. From the record, we are unable to discern the specific methodology employed by S. Gaudiano in making the present value calculations. Thus, petitioners have failed to establish that the method they used to compute the amount realized of the note was reasonable or had a basis in fact. We conclude that petitioners have not established that they are entitled to increase their section 1231 losses relating to the sale of the equipment by Four A. III. Bad Debt Deduction From 1988 to May 6, 1991, Appolo advanced significant amounts of money to Four A for its working capital needs. In 1991, petitioners, in their capacity as Four A shareholders,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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