June Cordes, et al. - Page 11




                                       - 11 -                                         
          Cordeses’ benefit.  Below, we set forth additional findings of              
          fact specific to these purported transactions and their tax                 
          consequences.                                                               
               A.  Loan Interest Allocation                                           
               Mr. Cordes lent $200,000 to CFC on August 20, 1991 (the                
          first $200,000 loan), and again on September 18, 1991 (the second           
          $200,000 loan) (collectively, the two $200,000 loans).  CFC                 
          repaid in full each of the two $200,000 loans by December 31,               
          1992.  On December 31, 1992, CFC paid Mr. Cordes $80,000, by                
          check, as interest on the two $200,000 loans.  The following day,           
          January 1, 1993, Mr. Cordes lent $80,000 to CFC (the $80,000                
          loan).9  CFC repaid in full the $80,000 loan by March 27, 1993.             
          On December 31, 1993, CFC paid Mr. Cordes $20,000 as interest on            
          the $80,000 loan.  The record does not contain any evidence of              
          indebtedness reciting the terms of the two $200,000 loans or the            
          $80,000 loan.                                                               
               CFC and the Cordeses treated the transfers from CFC to Mr.             
          Cordes of $80,000 and of $20,000 consistently as between                    
          themselves; CFC reported them as deductible interest expenses on            
          its 1992 and 1993 Forms 1120, U.S. Corporation Income Tax Return,           
          respectively, and the Cordeses reported them as interest income             



               9Mr. Cordes made this loan of $80,000 to CFC by endorsing              
          the $80,000 check he had received as interest on the two $200,000           
          loans the day before and returning it to CFC.                               





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