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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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Last modified: May 25, 2011