- 546 - demonstrate that the transactions had any substance. Respondent further determined that the sales were to a related party and were subject to section 267, which disallows losses between related parties.61 As of June 24, 1985, IRA's general ledger reflected a note receivable in the amount of $122,500 owing by Funding Systems. It further reflected that, on that same date, IRA received payments, leaving a $91,988 balance due on the receivable. LBG Properties, Inc. (LBG), is a subsidiary of IRA. IRA's general ledger reflected that IRA had had a note receivable of $39,500 owing by LBG. Sherwood Associates (the Sherwood partnership) is a partnership in which IRA was a partner. IRA's general ledger reflected that IRA had a note receivable of $47,925 owing by the Sherwood partnership. Tanglewood Properties, Inc. (Tanglewood), is a subsidiary of Holding Co. Prior to 1981, Holding Co. had paid or transferred $350,000 to Tanglewood. On its books, Holding Co. recorded this transaction as a note receivable owing by Tanglewood. On or before August 31, 1981, IRA acquired the Tanglewood receivable 61 Respondent conceded the adjustments relating to the capital losses claimed on the sales of stock of Brajda's, U.S. Mineral, Composite Container, Modular Power, and Forenergy. The remaining adjustments are in dispute.Page: Previous 536 537 538 539 540 541 542 543 544 545 546 547 548 549 550 551 552 553 554 555 Next
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