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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.
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Last modified: May 25, 2011