- 25 - 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.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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