- 13 - the Spencers did not report any interest income from SPC-SC and did not claim any interest deductions for amounts paid to SSI or SCNB. SPC-SC's corporate returns, Forms 1120S, did not reflect any amount on Schedule L as "loans from shareholders" for taxable years 1990, 1991, or 1992. The debts SPC-SC incurred in purchasing the assets from Mr. Spencer and Mr. Boozer were reflected on Schedule L as "mortgages, notes, and bonds payable in 1 year or more."12 SPC-SC's Schedules L, for taxable years 1990, 1991, and 1992, reflected that its capital stock was $1,000 and that its paid-in capital was zero. SPC-SC did not list the bank loan on its books as a capital contribution. SPC-FL Transaction Three years later, in a similar series of transactions, SSI nominally sold its Florida assets and operations to Mrs. Spencer, the Schroeders, and Lewis Smith (the purchasers) for $1,150,000. The purchasers subsequently nominally conveyed those same assets to a newly organized S corporation, SPC-FL, for $1,150,000. As in the case of the SPC-SC transaction, Mr. Spencer caused SSI to 12 The amounts reflected on SPC-SC's Schedules L as "mortgages, notes, and bonds payable in 1 year or more" are as follows: Year Beginning of Tax Year End of Tax Year 1990 $1,246,569 $1,170,308 1991 1,170,308 1,161,981 1992 1,161,981 1,170,119Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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