- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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