- 5 - Telim’s 1988 corporate Federal income tax return reflected a total of $15,603 as loans to shareholders. Telim’s 1989 corporate Federal income tax return reflected no income, no tax liability, and no loans to shareholders. This was the final corporate Federal income tax return filed on behalf of Telim. On their 1989 joint Federal income tax return, petitioners claimed a section 1244 ordinary loss of $28,000 relating to their Telim stock. On their 1990 joint Federal income tax return, petitioners did not claim any losses relating to their investment in Telim. On their 1991 joint Federal income tax return, petitioners deferred the $26,713 gain from sale of their California residence, and they claimed a $21,368 moving expense deduction. Petitioners did not claim thereon any losses relating to their investment in Telim. On audit of petitioners' 1989 joint Federal income tax return, respondent disallowed the $28,000 claimed section 1244 ordinary loss relating to petitioners’ Telim stock, and petitioners filed with regard thereto a petition with this Court in Nix v. Commissioner, docket No. 5120-93. Respondent and petitioners reached a settlement in that case in which $22,400 of the claimed $28,000 section 1244 ordinary loss was allowed to petitioners for 1989.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011