Khalil and Lana K. Hamdan - Page 2




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               The deficiency is based on an adjustment to the income of              
          petitioners’ wholly owned S corporation and a corresponding                 
          increase in petitioners’ distributive share of the S corporation’s          
          income.  The adjustment stems from the disallowance of: (1) A               
          deduction for a $300,000 “profit participation fee” purportedly             
          paid in 1989 by the S corporation to petitioners’ wholly owned C            
          corporation; and (2) travel and automobile expenses claimed by the          
          S corporation.  (An S corporation’s income is passed through to its         
          shareholders; thus, the disallowance of deductions claimed by an S          
          corporation results not only in an increase in the income of the S          
          corporation but also in an increase in the shareholders’                    
          distributive shares of the S corporation’s income.)                         
               In their petition, petitioners contest the increase to their           
          distributive share of the S corporation’s 1989 income, as well as           
          the imposition of the section 6662(a) accuracy-related penalty.  By         
          way of an amendment to their petition, petitioners assert                   
          entitlement to a business bad debt deduction in 1990, which, if             
          petitioners are correct, can be carried back to 1989, the year at           
          issue.                                                                      
               Accordingly, the issues for decision are:  (1) The propriety           
          of the $300,000 “profit participation fee” deduction claimed by             
          petitioners’ wholly owned S corporation; (2) the propriety of               
          travel and automobile expense deductions claimed by petitioners’            
          wholly owned S corporation; (3) whether petitioners’ advances to            






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