- 10 - during 1992. Amazona reported its taxable income on a cash method of accounting. On an amended 1992 return, Amazona reported an ordinary loss of $48,579. This loss resulted from payments by Amazona during 1992 for entertainment fees of $47,000, legal fees of $794, travel expenses of $743, and meals and entertainment expenses of $42. On his 1992 return, petitioner (as 100-percent shareholder of Amazona) claimed a "nonpassive loss" of $28,589 from Amazona. His return reflected Amazona to have had an ordinary loss of $48,579 for 1992, but further stated that only $28,589 of that loss was allowable to him for 1992 after application of the at risk provisions of section 465. Roadmaster Leasing In 1992, petitioner met with Lyle Schole, the promoter of a proposed venture called Roadmaster Leasing. They discussed entering into a limited partnership engaged in the business of buying late-model, used automobiles in the United States to resell in Latin America. Petitioner further met and discussed the proposed venture with Jose Candelario, an accountant Mr. Schole had retained to perform tax work for Roadmaster Leasing. Petitioner agreed to invest and purchase a partnership unit in Roadmaster Leasing for $25,000. On September 21, 1992, petitioner paid $5,000 to Mr. Schole as a downpayment on hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011