- 3 - During 1990, petitioner sold a business interest to the Chicago Board of Trade for $125,000. At the time of that sale, petitioner’s adjusted basis in that business interest was $16,081. (We shall refer to the amount petitioner received on the sale of its business interest (i.e., $125,000) reduced by petitioner’s adjusted basis in that interest (i.e., $16,081) as petitioner’s 1990 amount realized.) At all relevant times, petitioner through Mr. Duncan knew that at least a portion of the $125,000 that it received during 1990 on the sale of its business interest constitutes income to petitioner for that year. On or about April 13 and July 18, 1991, petitioner received checks totaling $49,500, which were not deposited into any bank account of petitioner but which Mr. Duncan retained and/or deposited in his bank account. At all relevant times, petitioner through Mr. Duncan knew that $40,000 of the total $49,500 in such checks constitutes income to petitioner for 1991. (We shall refer to such $40,000 of such checks as petitioner’s 1991 check amount.) During 1990 and 1991, respectively, petitioner made payments or other transfers to or on behalf of Mr. Duncan of amounts totaling $293,650.112 and $460,263.56. Petitioner failed to 2Of the $293,650.11 in payments or other transfers to or on behalf of Mr. Duncan that petitioner made during 1990, $9,610 was paid to Georgio Armani for the purchase of clothing for Mr. Duncan.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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