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sold to a related party after May 14, 1980?). And there is no
evidence as to whether the balloon payments due on July 11, 1993
(representing $747,000 of the total $947,000 sales price), were
ever made, received or reported.
Accordingly, we sustain respondent's determination that
Kanter had an additional net long-term capital gain of $378,800
in 1983 resulting from the installment sale of stock by the
grantor trusts.
Issue 11. Whether Kanter Is Entitled to Research and Development
and Business Expense Deductions From Immunological Research
Corporation for 1979
FINDINGS OF FACT
On their Federal income tax returns for 1979 through 1982,
the Kanters claimed $311,478, $10,962, $711, and $1,590 as
Kanter's distributive share of losses from Immunological Research
Corp. (IRC), an S corporation, allocable to three grantor trusts,
for which Kanter was the deemed owner; namely, Tablet Trust,
Capsule Trust, and Liquid Trust.
Although respondent issued notices of deficiency to Kanter
for the years 1979 through 1982, respondent did not disallow the
losses claimed by Kanter from IRC in the notices of deficiency.
However, in an Amendment to Answer in docket No. 3456-88,
respondent affirmatively alleged that Kanter's claimed loss in
the amount of $311,478 for 1979 was not allowable. Respondent
also asserted that any underpayment from the claimed loss from
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