Antonio and Joyce Rosario - Page 11

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          guarantee payments are not includable in petitioner’s income in             
          1993 because those payments were a loan.                                    
               As we have found that petitioners are not liable for the               
          deficiency, whether the period of limitations expired for the               
          1993 taxable year is moot.                                                  
               In reaching all of our holdings herein, we have considered             
          all arguments made by the parties, and to the extent not herein             
          discussed, we find them to be irrelevant or without merit.                  
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered for petitioners.            

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