WSB Liquidating Corporation - Page 8




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          issue, nor did Walter claim deductions for alimony payments for             
          taxable years 1984 through 1990 and 1994 through 1998.3                     
               Petitioner had retained earnings of $1,526,835 at the end of           
          1993, $1,752,421 at the end of 1994, and $2,037,873 at the end of           
          1995.  Petitioner did not pay any dividends during its existence.           
               In July 1997, petitioner sold substantially all of its                 
          assets to an unrelated third party.  In connection with the sale,           
          Barbara and Walter (on his own behalf and acting for petitioner)            
          executed an agreement releasing petitioner from its obligations             
          under the Pension Agreement.  At the time of trial, Barbara and             
          Walter were deceased.                                                       
               In the notice of deficiency, respondent determined that                
          petitioner was not entitled to deductions for wages it claimed in           
          the amounts of $24,553 for 1993, $22,854 for 1994, and $23,499              
          for 1995.4  Respondent further determined that petitioner was               
          liable for accuracy-related penalties for underpayments due to              
          the claimed deductions for wages.                                           









               3 The record does not reveal what return positions Walter              
          may have taken in 1991 through 1993.                                        
               4 Respondent determined other adjustments not at issue in              
          the instant case.                                                           





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