Edwin A. Helwig - Page 7




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          projected income of $50 million for K&H.  K&H was not directly               
          involved in the research and development of the vending machine.             
               K&H determined the amount of partial worthlessness of the               
          advances made to Snacks each year by comparing the prior year’s              
          ending advance balance with Snacks’ cumulative losses to arrive              
          at a ratio.  The resulting ratio was then applied to the prior               
          year’s ending advance balance to arrive at the claimed writeoff.             
          Snacks’ net worth as of July 31, 1990, 1991, 1992, 1993, and 1994            
          was a negative $1,244,172, $2,107,158, $2,571,348, $3,019,739,               
          and $3,126,138, respectively, each caused by an excess of                    
          liabilities over assets.  For its fiscal years ended April 27,               
          1991, and April 25, 1992, K&H claimed that the advances to Snacks            
          had become partially worthless (a bad debt) and deducted the                 
          amounts of $579,607 and $461,970, respectively.  Respondent, in              
          the notice of deficiency, determined that the claimed bad debt               
          deductions were not allowable.                                               
               K&H advanced Snacks more than $700,000 through April 1990               
          and additional amounts of $320,000 and $260,000 during the fiscal            
          years ended April 1991 and 1992.  For the period ended December              
          31, 1993, K&H, based on the accountant’s advice, sold to the                 
          accountant $650,000 of the notes for $1,000 in an attempt to “fix            
          the time and amount of the loss.”  Respondent determined that the            









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