Greg R. Vinikoor and Melissa D. Vinikoor - Page 6

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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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