Carol M. Read, et al. - Page 16




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          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.                                              





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