- 4 - only being payable on July 1, 1988, and each July 1 thereafter until July 1, 1993, when the entire principal balance together with accrued interest shall be due and payable. Notwithstanding that it was executed on February 14, 1989, the purchase agreement recites that it was made and entered into as of November 1, 1987. In 1990, 1991, and 1992, petitioners received payments from Chef-Reddy (the Chef-Reddy payments) in the amounts of $283,874, $165,956, and $64,719, respectively, which payments petitioners did not report on their income tax returns for those years. Respondent determined deficiencies in petitioners' Federal income taxes for 1990, 1991, and 1992 on the grounds, in part, that the Chef-Reddy payments were items of gross income improperly omitted from gross income by petitioners. Petitioners contend that the Chef-Reddy payments are not items of gross income because they represent a return of capital; i.e., the Chef-Reddy payments represent amounts that, previously, should have been taken into income.Discussion1 1 Rule 151(e) deals with the form and content of briefs, and provides as follows: (e) Form and Content: All briefs shall contain the following in the order indicated: (1) On the first page, a table of contents with page references, followed by a list of all citations arranged alphabetically as to cited cases and stating the pages in the brief at which cited. Citations shall be in italics when printed and underscored when typewritten. (2) A statement of the nature of the controversy, (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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