- 5 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011