John C. Bowden and Karol Bowden - Page 5




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          the note payable and $220,468 for the note assumed by the                   
          corporation for petitioner's liability to his ex-wife.                      
               Respondent also denied $13,885 in business expenses for 1991           
          and determined petitioners received constructive dividend income            
          in the amounts of $28,197 for 1991 and $13,651 for 1992.  In                
          addition, their taxable income was increased in the amounts of              
          $32,976 and $1,547 for 1991 and 1992, respectively, pursuant to             
          the passive activity loss limitation provisions of section 469.             
          For taxable years 1992 and 1993, respondent characterized                   
          petitioners' reported self-employment income as wage income and             
          disallowed deductions of $10,000 and $9,500, respectively, for              
          their contribution to a Simplified Employee Pension/Keogh Plan.             
               Petitioners filed a petition with the Court, alleging error            
          in each determination contained in the notice of deficiency.                
          Respondent filed an answer denying each allegation contained in             
          the petition.                                                               
               Respondent subsequently filed an amendment to answer                   
          asserting that the insurance premium renewals transferred to the            
          corporation had a basis of zero, not $245,000 as stated by                  
          petitioners in their 1991 tax return.  The amendment to answer              
          also asserted that there was a deficiency attributable to gain              
          resulting from the difference between the $220,468 liability                
          assumed by the corporation and the adjusted basis of all the                







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