- 6 - received from JCC into his personal bank account. JCC booked the transferred amount as an amount payable from petitioner. At the time petitioner received the transferred amount JCC was insolvent and had not filed its U.S. Corporation Income Tax Returns for its fiscal tax years ended June 30, 1986, 1987, and 1989, respectively. Although petitioner was aware that JCC was insolvent, he believed that JCC’s net operating losses would result in no Federal tax liability for JCC. It was usual for petitioner to advance or loan funds to JCC and/or its subsidiaries. Prior to receiving the $286,737.27 from JCC, there had been regular advances and repayments of funds between JCC and petitioner. Petitioner’s Income Tax Returns On his 1991 Form 1040, U.S. Individual Income Tax Return, petitioner reported interest income from the Johnson Corp., in the amount of $25,924. That amount represented interest on obligations owed to him by the Johnson Corp. On his 1992 individual Federal income tax return, petitioner also reported wages from JCC’s subsidiaries (the Johnson Corp. and Heritage Development Co.) in the amounts of $50,000 and $56,250, respectively. Petitioner’s reported income of $304,637 did not include the $286,737.27 received from JCC. Tax Liability of JCC JCC’s corporate income tax return, for its fiscal tax yearPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011