- 4 - to Florida’s west coast, the acquaintance transferred the condominium to Mr. Peacock subject to a mortgage.2 Mr. Peacock later sold the condominium but never transferred any of the money to the dealership. The dealership, an S corporation for Federal income tax purposes, claimed a $50,000 bad debt deduction for 1995 on account of the loan. Respondent disallowed that deduction. On May 18, 1998, the dealership’s 51-percent shareholder agreed to the disallowance. At that time, Mr. Peacock continued to own the remaining stock of the dealership. Petitioners organized Profitable Management Services, Inc. (PMSI), an S corporation, on December 2, 1993. PMSI’s president and only shareholder was Ms. Peacock. Both she and Mr. Peacock were paid employees of PMSI. But for services connected with the fishing activity, the only service that Ms. Peacock performed for PMSI was answering its telephones. From 1994 through 1997, PMSI paid the following amounts to petitioners and to its other employees: Year Mr. Peacock Ms. Peacock Other employees 1994 -0- -0- -0- 1995 $7,000 $7,000 $30,098 1996 26,000 19,500 72,439 1997 23,000 25,500 1 1 The record does not disclose this amount. 2 The record does not disclose either the value of the condominium or the amount of the mortgage.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