- 16 - income tax (tax) return for each of those years. Ms. Read did not report any income with respect to her transfer of MMP stock to MMP, except for the interest payments under the installment promissory note that MMP made to her during 1988, 1989, and 1990. She reported those interest payments as interest income in her tax returns for those years. Mr. Read did not report in his tax returns for 1988, 1989, and 1990 any income with respect to Ms. Read’s February 5, 1986 transfer of MMP stock. Respondent determined in the notice issued to Ms. Read for 1989 and 19905 that the principal payment under the installment promissory note that MMP made to her during each of those years constitutes long-term capital gain.6 Respondent made no determi- nations in that notice with respect to the interest payments under the installment promissory note that Ms. Read reported as interest income in her returns for those years. Respondent determined in the notice issued to Mr. Read for 1988, 1989, and 1990 that the principal and interest payments under the installment promissory note that MMP made to Ms. Read during those years are constructive dividends to Mr. Read. Respondent determined in the notice issued to MMP for 1988, 5The notice issued to Ms. Read did not relate to Ms. Read's taxable year 1988. 6The parties stipulated that Ms. Read's basis in the MMP stock that she owned was zero.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011