Daniel F. Nix and Gayle H. Nix - Page 5




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               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.                                                       





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