- 11 - Year Liabilities Equity 1987 $887,937 ($204,556) 1988 954,758 (315,821) H. Tax Returns On its 1986 return, Cabana Boy reported that loans from shareholders were $391,045 at the beginning of 1986 and $137,102 at the end of 1986. Hyman prepared Cabana Boy's Forms 1120, U.S. Corporation Income Tax Returns, for its taxable years ending November 30, 1987 through 1990. On June 22, 1995, Mrs. Rosenberg signed Cabana Boy's corporate tax returns as president. Petitioners did not treat their advances to Cabana Boy as loans or claim bad debt deductions on their individual income tax returns. I. Dissolution of Cabana Boy Cabana Boy was dissolved on March 24, 1993. Petitioners never demanded repayment of any money spent on the Cabana Boy project. OPINION Petitioners offer several alternative theories to support the deduction of their advances to Cabana Boy: (A) The advances were debt, not equity; (B) their advances to Cabana Boy were business expenses of Cabana Boy which petitioners may deduct as if Cabana Boy were an S corporation, or they were Cabana Boy’s alter ego; (C) petitioners may deduct the advances under section 212 as expenses to produce income; and (D) petitioners may deductPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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