- 547 - from Holding Co. in exchange for a receivable owing by IRA to Holding Co. Pursuant to Kanter's instructions, on December 1, 1985, IRA sold the receivables due from Tanglewood, LBG, and Sherwood to Kanter for $10,000, $10, and $1,000, respectively, and sold the receivable due from Funding Systems to Holding Co. for $20,000. With respect to each of the sales, Kanter determined the sales price. The sale prices were not determined by arm’s-length negotiations. Neither Kanter nor Holding Co. paid cash to IRA for the receivables. Instead, receivables due from Kanter and Holding Co., in the amounts of the respective sale prices of the receivable, were recorded through adjusting journal entries on the books of IRA. The sole purpose of the sales was an attempt by Kanter to provide a basis for IRA to claim a deduction for Federal income tax purposes. According to IRA's general ledger, on February 19, 1986, the $39,500 lent to LBG by IRA and the $47,925 lent to Sherwood by IRA was repaid to IRA in full. On February 28, 1986, Tanglewood repaid $6,000 of its loan from IRA, and on June 24, 1986, IRA received repayments on the Funding Systems note in the amounts of $10,000, $4,500, and $10,000. The payments from Funding Systems were credited to Holding Co. by an adjusting journal entry on IRA's general ledger. The payments from Sherwood and LBG werePage: Previous 537 538 539 540 541 542 543 544 545 546 547 548 549 550 551 552 553 554 555 556 Next
Last modified: May 25, 2011