- 5 - the instant case. A taxpayer may pay the deficiency and interest at any time after the notice of deficiency is mailed and still be entitled to his "day" in this Court. Sec. 6213(b)(4); Estate of Richter v. Commissioner, 16 B.T.A. 936, 937 (1929). The taxpayer who so pays the deficiency and interest and then prevails will be entitled to a refund or credit, sec. 6512(b)(3)(A), as well as interest thereon. Sec. 6611.4 2. Bad Debt Deduction for 1981 From January 1, 1979 through June 23, 1981, petitioner John J. Kaiser (petitioner) was the 100-percent shareholder of MACS Corp. (MACS), an S corporation in the business of buying and selling cleaning supplies in the Bridgeport, Connecticut, area. During 1979 and subsequent years through 1981, petitioner advanced a total of $111,725 to MACS. On its 1981 Form 1120S (U.S. Small Business Corporation Income Tax Return) MACS reported paid-in or capital surplus in the amount of $1,000 and loans from shareholders in the amount of $110,725. On their 1979, 1980, and 1981 Federal income tax returns, petitioners claimed losses from MACS in the total amount of $95,661 and reduced petitioner's basis in the shareholder loans 4 Petitioners have not presented us with any argument that the alleged payments were improperly applied by respondent or that they were deposits against the deficiencies determined by respondent. See Risman v. Commissioner, 100 T.C. 191 (1993). Indeed, there would be insufficient facts in the record before us to decide such issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011