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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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