Charles A. Buda and Annette H. Buda - Page 3




                                        - 3 -                                         

          increase in insurance costs, permanently closed the wave pool               
          facility and attempted to sell the wave pool equipment.  When               
          these attempts were unsuccessful, MOC dismantled the equipment              
          and moved it to another location where it remained in storage               
          through 1988.                                                               
               In 1984, Mr. Buda began converting 5 Acre into Z Buda                  
          Outlets, a retail outlet mall.  MOC and Mr. Buda borrowed                   
          $1,461,000 from Citizens National Bank (the bank).  Proceeds of             
          the loan were used to fund construction work on 5 Acre.  As                 
          collateral for the loan, MOC assigned the bank the leasehold                
          interest in, and right to all rental income from, 5 Acre.  As               
          additional collateral, Mr. Buda assigned interests in two other             
          parcels of realty that he held in his individual capacity.                  
               The shops in the mall were leased to various businesses.               
          Mr. Buda signed, either in his individual capacity or as                    
          president of MOC, the leases and related amendments and                     
          assignments.  All cash transactions relating to the operation of            
          the mall were processed through a bank account under the name "Z            
          Buda Factory Outlets".  The mall's income and expenses were                 
          reported on petitioners' records and tax returns.  The expenses             
          reported by petitioners for 1985, 1986, 1987, and 1988 included             
          $30,000 in rent payments, which were reported as income on MOC's            
          records and tax returns.                                                    
               On December 30, 1988, MOC was liquidated.  Its leasehold               
          interest in 5 Acre and all other corporate assets were                      
          distributed to Mr. Buda.  On his 1988 return, Mr. Buda reported             

Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011