Mark J. Hanna, P.C., Transferee - Page 13




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          Office Equipment                                                             
               We disagree with respondent's conclusion that the $15,000               
          listed in the Internal Document for office equipment represents              
          the amount of the office equipment on the transfer date.                     
               Hanna testified that the $15,000 listed in the Internal                 
          Document represents the original cost of the office equipment and            
          that the actual amount of office equipment transferred was only              
          $4,295.                                                                      
               We regard Hanna's testimony as to the amount of the office              
          equipment to be credible.  Accordingly, we conclude that the                 
          amount of Associates PC's office equipment transferred to Hanna              
          PC was $4,295.                                                               

          Interest in a Lawsuit                                                        
               Based on Hanna's own testimony, we conclude that the                    
          appropriate amount for the interest in a contingent fee lawsuit              
          on the transfer date was $10,000, as determined by respondent.               
               Hanna PC claims that because Associates PC was a cash basis             
          taxpayer none of the amount for the interest in a lawsuit should             
          be reflected in calculating the amount of the assets transferred.            
          As stated previously, we reject this argument.                               

          Accounts Payable                                                             
               We agree with respondent that Associates PC's accounts                  
          payable that were assumed by Hanna PC should reflect only                    






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