- 3 - Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties have stipulated some of the facts, which are so found. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. When they filed their petition, the individual petitioners were married and resided in Dallas, Texas. Crestmark is a corporation formed under the State laws of Texas. When it filed its petition, Crestmark’s principal office was located in Dallas, Texas. Since 1976, Winona Mowrey (Mowrey) has been employed in the mortgage banking business as a loan officer. During the year in issue, Mowrey was employed as loan officer and manager of a branch office of Fort Worth Mortgage Corp. and Colonial Savings, F.A. (Fort Worth Mortgage), and reported wage income of 1(...continued) (1991); Money v. Commissioner, 89 T.C. 46, 48 (1987); Grossman v. Commissioner, T.C. Memo. 1996-452, supplemented by T.C. Memo. 1997-451, affd. __ F.3d __ (4th Cir., June 28, 1999). On brief, respondent indicates that because of a miscalculation, the amount of imputed interest income was overstated in the notice of deficiency. We expect respondent to give Crestmark the benefit of the revised computation in the Rule 155 computation, and in accordance with representations in respondent’s trial memorandum and opening statements at trial, to make appropriate adjustments to Crestmark’s taxable income with respect to the income reassigned from Crestmark to the individual petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011