June Cordes, et al. - Page 4




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          Docket No. 19278-97                                                         
          Petitioner Eddy Ben Cordes:                                                 
                                             Additions to tax                         
                    Year      Deficiency     sec. 6651(a)(1)                          
                    1983      $190,450          $47,613                               
                    1989      101,600           25,400                                
          Docket No. 19279-97                                                         
          Petitioner June Cordes:                                                     
                                             Additions to Tax                         
                    Year      Deficiency     sec. 6651(a)(1)                          
                    1991      $286,654            -0-                                 
                    1993      28,767         $7,192                                   
                    1994      1,749,930      437,483                                  
          Collectively, the above five cases are referred to as the gift              
          tax cases.                                                                  
               After concessions,5 the issues for decision are:                       
               (1)  As to the income tax cases, whether respondent abused             
          his discretion in determining that the interest charged for 1992            
          and 1993 on loans between Edmund J. Cordes (Mr. Cordes) and                 
          Cordes Finance Corp. (CFC) was unreasonable and excessive and in            
          recharacterizing the amounts transferred to reflect an arm’s-               
          length rate of interest under section 482;                                  





               5Many issues in these consolidated cases have been settled             
          or conceded by the parties, or are deemed conceded by this Court.           
          Other issues raised by the parties are computational in nature.             
          In the interest of space, these conceded, deemed conceded,                  
          computational, and settled issues, and their respective                     
          dispositions, are set forth in Appendix B, Summary of Conceded,             
          Deemed Conceded, Computational, and Settled Issues.  We                     
          incorporate those dispositions into our opinion by this                     
          reference.                                                                  




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