Gregory H. and Elizabeth A. Price - Page 4




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          general ledgers, however, were retained by the partnership and by           
          petitioner for only a short period of time and were not available           
          at the trial.                                                               
               Petitioner maintained what he refers to as monthly summary             
          records with respect to funds received from rental of videos.               
          The summary records also were not available at the trial.                   
               There was maintained for each Store a separate bank account            
          at Valley National Bank.  Funds received from rental of videos              
          were deposited every few days into the bank accounts maintained             
          for the Stores.                                                             
               Most of the funds deposited in the bank accounts represented           
          cash received by the Stores from the rental of videos.  Funds               
          deposited into the bank accounts also represented checks received           
          by the Stores from the rental of videos and funds received by the           
          Stores from credit card companies for video rentals which had               
          been paid by customers with credit cards.                                   
               Stores 1, 2, and 3 were sold either in 1987 or in the                  
          beginning of 1989, and there is no issue between the parties as             
          to the income relating to Stores 1, 2, and 3.                               
               For 1989 and 1990, the partnership timely filed partnership            
          Federal income tax returns and reported gross receipts and, after           
          expenses, ordinary losses relating to Stores 4 and 5 as follows:            








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