- 5 -
Shareholder No. of Shares Percent
Charles C. Allen, Jr. 50 16.67
Charles C. Allen III 50 16.67
Warren L. Allen 15 5.00
Warren L. Allen, Jr. 85 28.33
John R. Allen 50 16.67
John R. Allen, Jr. 50 16.67
Total 300 100.00 (rounded)
During its 1994 and 1995 taxable years, Foods incurred wages
which qualified for the TJC. Foods claimed TJCs of $456,264 and
$259,434 on its 1994 and 1995 Federal income tax returns,
respectively, and reported to each petitioner on his Schedules
K-1, Shareholder’s Share of Income, Credits, Deductions, etc.,
his proportionate shares of those credits. The Schedules K-1
reported the proportionate shares as follows:
Shareholder 1994 1995
Charles C. Allen, Jr. $76,044 $43,239
Charles C. Allen, III 76,044 43,239
Warren L. Allen 22,813 12,972
Warren L. Allen, Jr. 129,275 73,506
John R. Allen 76,044 43,239
John R. Allen, Jr. 76,044 43,239
Total 456,264 259,434
For Federal income tax purposes, Foods reduced its deduction
of wages by the amount of the TJC as required by section 280C(a)
and reported to each petitioner on his Schedules K-1 his
proportionate share of the resulting net income (Foods’ resulting
net income). Each petitioner computed his regular income tax
liability for 1994 and 1995 by including in his taxable income
his proportionate share of Foods’ resulting net income.
Page: 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