Glenn H. and Diane J. Flood - Page 4




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               Petitioner and Hammontree filed a partnership tax return for           
          Glenwood for the calendar year 1988.  For the 1988 tax year,                
          Glenwood reported ordinary losses of $517 and claimed $5,000 in             
          section 179 expenses.  Glenwood’s Schedule K for 1988 reflected             
          that petitioner and Hammontree each owned 50 percent of the                 
          partnership.  Petitioners reported flowthrough activity from                
          Glenwood for tax years 1988 through 1992 on their Forms 1040,               
          U.S. Individual Income Tax Return.                                          
               Effective February 28, 1989, Glenwood became incorporated as           
          Glenwood Wrecker Service, Inc., and the Glenwood partnership was            
          terminated.  The partnership assets and liabilities were                    
          exchanged for all of the issued stock in Glenwood.                          
          Additionally, a short-year partnership tax return was filed for             
          the period ending February 28, 1989.  The partnership reported              
          ordinary income of $788 for the short tax year ending February              
          28, 1989.  Petitioner’s ending basis in Glenwood partnership and            
          his beginning basis in Glenwood corporation was $13,914.                    
               On April 25, 1989, petitioner and Hammontree personally                
          guaranteed a bank loan to Glenwood in the amount of $43,080.  The           
          loan was secured by Glenwood’s assets, which consisted of six tow           
          trucks and one office trailer.  Petitioner and Hammontree agreed            
          that $29,788.59 should be removed from the corporation by                   
          Hammontree and paid to petitioner in payment for Hammontree’s               
          one-half interest in the business.  The following day, April 26,            
          1989, petitioner received a $29,788.59 corporate check, signed by           




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