- 414 - 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 fromPage: Previous 404 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 Next
Last modified: May 25, 2011