Shane Michael Optical, Co. - Page 4




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          Year      Travel      Automobile    Insurance    Total                      
          1993      $27,847      $18,839       $4,803     $51,489                     
          1994      27,847       22,014        8,031      57,892                      
          1995      29,023       37,142        7,796      73,961                      
          Shane Michael agrees with this determination.  With the exception           
          of a $9,374 deduction for taxes claimed in 1995, respondent                 
          disallowed no other amount that Shane Michael reported as a                 
          deduction for the subject years.                                            
               Respondent also determined that the adjustment to Shane                
          Michael's taxable income meant that the Shanes received                     
          constructive dividends of $51,849 in 1993, $57,892 in 1994, and             
          $72,785 in 1995.  The Shanes agree with this determination, and             
          they agree with another determination that, for each year in                
          issue, they did not include in their gross income $37,500 of                
          interest income received from Shane Michael.  Mr. Shane had lent            
          money to Shane Michael before the subject years, and he received            
          during the subject years interest on those loans.  Mr. Shane did            
          not receive for the subject years a tax form reporting that he              
          had received that interest.                                                 
               Mr. Shane uses his automobile for business.  He also                   
          traveled on business worldwide and frequently up until the spring           
          of 1993 when he was diagnosed with cancer and began receiving               
          medical treatment.  At that time, Mr. Shane also stopped keeping            
          an expense log which, in previous years, he gave to Shane                   
          Michael's bookkeeper for reimbursement of his business expenses             
          and to his accountant to prepare the Shanes' personal income tax            
          returns.  Shane Michael continued to pay Mr. Shane an expense               


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Last modified: May 25, 2011