- 7 - Yearend Financial Information 1993 1994 1995 1996 Gross Revenue $ 359,714 $5,246,515 $ 8,840,065 $13,580,098 Total Assets 4,287,799 7,391,115 12,001,652 14,611,042 Total Liabilities 4,119,859 6,638,531 10,443,799 11,392,737 Shareholder Equity 167,940 752,584 1,557,853 3,218,305 Debt-to-Equity Ratio 25:1 9:1 7:1 4:1 As of the time of trial in 2002, petitioner had yet to declare or pay a cash dividend. At the end of 1993, petitioner’s basis in its capital assets including land, buildings, equipment, vehicles, tooling and equipment was $3,598,463. For 1993-1996 and for Federal income tax purposes, petitioner was a cash basis taxpayer. On petitioner’s timely filed 1996 corporate Federal income tax return, an interest deduction of $93,746 was reflected for the payments designated as interest that petitioner made in 1996 on the debenture notes. On audit, respondent determined that for Federal income tax purposes the total debenture funds of $1,337,500 represented equity to petitioner rather than debt, and respondent denied petitioner’s claimed $93,746 interest deduction relating to the designated interest paid in 1996 on the debenture funds. OPINION As a general rule, section 163(a) provides that a deduction shall be allowed for all interest paid on indebtedness.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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