James W. and Laura L. Keith - Page 8




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          calculated as the difference between the sales price and GIA’s              
          basis, was $58,373, $62,517, and $11,500 for agreements executed            
          in 1993, 1994, and 1995, respectively.                                      
          GIA’s Accounting and Reporting                                              
               With their 1993, 1994, and 1995 Federal income tax returns,            
          petitioners included Schedules C, Profit or Loss From Business,             
          with respect to GIA.  On each such Schedule C, petitioners                  
          indicated GIA’s accounting method by checking the box labeled               
          “Accrual”.  A like designation was made on Schedules C filed with           
          returns for the preceding years 1984 through 1992.                          
               As regards accounting for the above-described real estate              
          transactions in particular, the methodology generally utilized by           
          petitioners has been stipulated by the parties.  During the term            
          of a contract for deed, petitioners would report as income the              
          interest received on the promissory note entered into in                    
          conjunction with the contract.  The portion of any payment                  
          allocable to principal would be treated as a deposit on the                 
          purchase and would be recorded as a liability on the books of the           
          company.  If a property were repossessed prior to completion of             
          the contract, this deposit would be applied first to repairs and            
          maintenance, and any remaining amount would be reported as                  
          miscellaneous income.  The properties would also be depreciated             
          by GIA during the payment period.                                           








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