Gregory H. and Elizabeth A. Price - Page 9




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          obligated to transfer to the partnership up to $100,000 to                  
          reimburse the partnership for costs of the improvements.  During            
          1989, the partnership received from Peoria $99,946 to make the              
          improvements to Store 5.                                                    
               In November of 1989, petitioner leased for a period of                 
          10 years from the College Park Partnership (College Park) a                 
          portion of a building for Store 6.  Under terms of the lease,               
          petitioner was obligated to make certain capital improvements to            
          the building, and College Park was obligated to transfer to                 
          petitioner up to $70,000 to reimburse petitioner for costs of the           
          improvements.  During 1989, petitioner received $56,921 from                
          College Park to make the improvements to Store 6.                           
               In 1989, Store 5 and in early 1990 Store 6 were opened and             
          conducted business, and it appears from the evidence that the               
          required improvements to the buildings were made and that the               
          above funds were received from Peoria and from College Park by              
          the partnership and by petitioner as reimbursement for costs of             
          the improvements.                                                           
               During 1990, petitioner received $8,465 from College Park to           
          make improvements to Store 6.                                               
               On the partnership's and on petitioners' 1989 income tax               
          returns, the $99,946 the partnership received from Peoria in 1989           
          to make improvements to Store 5 was not reflected as income of              
          the partnership.  Also, on petitioners’ joint Federal income tax            





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