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determinations in the FPAA’s that Management had $1,450,793 in
taxable distributions for the 1988 tax year and $8,160,745 in
taxable distributions for the 1990 tax year. See Rules 142(a),
240(a). The Court further holds that Management had $2,648,902
in taxable distributions (the $10,809,647 respondent originally
determined, less the $8,160,745 respondent now states is properly
allocable to 1990) for the 1989 tax year.
Petitioners offered no evidence concerning the 1989 and 1990
discharge of indebtedness adjustments respondent determined
Management had from the forgiveness of amounts owed by it to Hoyt
& Sons Ranch Properties on land leases from 1983 through 1989.
On brief, respondent acknowledges that the same $4,984,403 amount
was included in both 1989 and 1990. Respondent now states he
believes this $4,984,403 of income should be recognized by
Management for 1990. Consequently, the Court sustains
respondent’s determination in the FPAA that Management had
$4,984,403 of discharge of indebtedness income for the 1990 tax
year. See Rules 142(a), 240(a). The Court further holds that
Management had no discharge of indebtedness income for the 1989
tax year.
To reflect the foregoing and the parties’ concessions,
Decisions will be entered
under Rule 155.
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