-60- We have found that Robert sold SSC to Maerki. In 1982, SSC paid $51,923.29 to SSI, of which $1,923.29 was interest. In 1982, SSC paid $10,000 to Robert. On their late-filed 1982 tax return, petitioners acknowledged $61,923 gain from this transaction, thereby conceding that they did not have any as-yet- unrecovered basis in SSC. Also, petitioners do not contend that they should be taxable on only 76 percent of the SSI receipts, because of Doyle's 24-percent interest in SSI. Respondent does not contend that petitioners had any additional income from the transaction and agrees with petitioners' long-term capital gain treatment of all but the interest component. We conclude that the record clearly shows that $1,923.29 of SSC's payment to SSI was interest, and we have so found. Supra N. Second Sale of Interest in Structured Shelters of Cincinnati. We hold for respondent on this issue. Petitioners failed to file a timely 1982 tax return. In fact, petitioners' 1982 tax return was filed after the notices of deficiency were issued in the instant case. In their late-filed 1982 tax return petitioners acknowledged a tax liability of $3,029. Our findings show that petitioners' 1982 income subject to tax is far greater than what they reported on their 1982 tax return. There is no indication of offsetting deductions or credits.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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