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time until October 15, 1991. Petitioners did not list any tax
due on the additional extension of time request.
Petitioners mailed their 1990 Federal income tax return on
October 15, 1991, listing their amount owed as $20,306 (after
prepaid withholding amounts of $3,941) but did not pay any amount
of money with the return. On April 20, 1992, petitioners filed
an amended 1990 return listing an increase in their total tax
liability of $24,124, for a total amount owed of $43,203 after
withholding. Petitioners filed a second amended 1990 return on
October 30, 1992, listing their amount owed as $19,848. A
statutory notice of deficiency was mailed to petitioners on June
16, 1994, and addressed petitioners' original and first amended
1990 returns.
Issue 1. Transfer of Shares of Price Co. Stock
Respondent determined that the October 30, 1987, and
December 10, 1987, transfers of 4,5003 and 2,000 shares of Price
Co. stock, respectively, were gifts, with a basis of 10 cents per
share, Drachman's basis. Petitioners assert that these transfers
of stock were valid loans, and that they are therefore entitled
3 Petitioners repeatedly argue at trial and on brief that
Drachman transferred 5,000 shares of Price Co. stock on Oct. 30,
1987; however, their account statement from the period of Sept.
26, 1987, through Oct. 30, 1987, indicates that only 4,500 shares
were transferred on that date.
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