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Loans From Bonnevista and Castle Towers to Petitioner
After filing Form 1120S, U.S. Income Tax Return for an S
Corporation, for its 1991 taxable year, Bonnevista filed no
subsequent income tax return.5 The balance sheet attached to the
1991 Form 1120S reflects loans to petitioner of $2,148,481 as of
the beginning of the tax year and $2,244,164 as of yearend.
After filing Form 1120S for its 1990 taxable year, Castle
Towers filed no subsequent return.6 The balance sheet attached to
its 1990 Form 1120S reflects yearend loans to petitioner of
$633,329.
Petitioner’s Ownership Interest in Fantastic Foods
In 1993, petitioner was president and majority stockholder
of Fantastic Foods, Inc., which holds exclusive rights to Dairy
Queen franchises in two counties in Florida. The corporation has
several affiliated corporations also known as Fantastic Foods.
The 1992 Federal corporate income tax return of one of those
affiliated corporations, Fantastic Foods, Inc. (Delaware),
indicates that it is wholly owned by petitioners’ son, William
5 The 1991 Form 1120S, U.S. Income Tax Return for an S
Corporation, does not indicate that it is the final return of
Bonnevista Terrace, Inc. (Bonnevista).
6 The 1990 Form 1120S does not indicate that it is the
final return of Castle Towers, Inc. (Castle Towers). On Schedule
E, Supplemental Income and Loss, of their 1991 joint Federal
income tax return, petitioners reported both passive and
nonpassive income from Castle Towers.
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Last modified: May 25, 2011