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               For FYE May 31, 1994, petitioner reduced its income by                 
          $6,085,248.18  This amount consisted of the ending balance of               
          G�nther’s intercompany account as of May 31, 1994, that had not             
          yet been written off for Federal income tax purposes ($2,375,788)           
          and the amount of G�nther’s guaranteed bank loans petitioner                
          assumed ($3,709,460).                                                       
          X.  Notice of Deficiency                                                    
               In the notice of deficiency, respondent disallowed                     
          petitioner’s deductions for bad debts and worthless stock                   
          attributable to G�nther that were claimed for FYE May 31, 1992              
          and 1993, increased petitioner’s income for FYE May 31, 1994, and           
          reduced petitioner’s net operating losses for FYE 1992, 1993, and           
          1994, accordingly.  Respondent recharacterized the disallowed               
          deductions as long-term capital losses and recomputed the net               
          operating loss carrybacks allowable for FYE 1989, 1990, 1991, and           
          1992.  Respondent also determined that other adjustments were               
          required, which have since been resolved by agreement or are                
          computational.                                                              
               18In the notice of deficiency, respondent proposed an                  
          adjustment increasing petitioner’s income by $6,085,248.  For               
          briefing and argument purposes, however, the parties have treated           
          the disputed adjustment as the disallowance of a bad debt                   
          deduction.                                                                  
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