Richard L. and Kelly D. Robson - Page 8




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          Nebraska’s business, York wrote off the $151,890 and paid $7,000            
          of Mid-Nebraska’s accounts payable, for a total purchase price of           
          $158,890.                                                                   
               On April 22, 1993, petitioner, on behalf of Mid-Nebraska,              
          and Sack, on behalf of York, executed an addendum to the                    
          acquisition agreement purportedly changing the allocation of the            
          sale price on assets other than fixed assets as follows:                    
          Item                     Amount                                             
                    Employment agreements          $16,372                            
                    Customer list                  130,978                            
                    Noncompete                       1,489                            
                    Total                        148,839                              
               Petitioner signed and filed Mid-Nebraska’s Form 1120, U.S.             
          Corporation Income Tax Return, for the year ended December 31,              
          1992 (1992 return), on October 15, 1993.  The 1992 return                   
          reported, among other things, a capital gain of $125,645 and                
          ordinary gain of $13,760 from the sale of property consisting of            
          “vehicle, accts receivable, non-compete, employment agreements,             
          customer list, goodwill”.  Form 4797, Sales of Business Property,           
          filed with the 1992 return showed the following calculation of              
          the capital gain and ordinary gain:                                         














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