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Deposits and Other Checks Relating to
the $55,753 TexAmBkSW Loan -- 1987 and 1988
Respondent argues that petitioner failed to pass through to
TexAmBkSW and should be taxed on $4,228 in 1987 and $402 in 1988 that
petitioner received from 2618 Inc in order to pay interest due on the
$55,753 TexAmBkSW loan (see supra p. 7). Petitioner argues that he
passed through the disputed funds to TexAmBkSW and should not be
taxed thereon. For 1987 and 1988, evidence in the record indicates
that petitioner paid $7,254 and $10,361, respectively, to TexAmBkSW
(see supra pp. 14-15), and no evidence indicates that petitioner or
2618 Inc owed any separate debt obligation to TexAmBkSW other than
the above $55,753 loan on which interest was due. We conclude that
petitioner, on behalf of 2618 Inc, passed through the disputed $4,228
and $402 to TexAmBkSW as payments on the $55,753 loan and that these
disputed funds should not be treated as taxable income to petitioner.
Deposits Relating to the $275,000
TexGuarantyBk Loan -- 1987 and 1988
Respondent argues that petitioner failed to pass through to
TexGuarantyBk $22,149 in 1987 (see supra p. 8) and $29,5321 in 1988
that petitioner received from 2618 Inc in order to pay interest due
on the $275,000 TexGuarantyBk loan. Petitioner argues that he passed
1 This $29,532 represents $12,251 that petitioner allegedly
failed to pay as interest to TexGuarantyBk on the $275,000 loan,
and the $17,281 that petitioner received from 2618 Inc and used
for personal purposes (see supra pp. 7-8).
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