Erickson Post Acquisition, Inc. - Page 7

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               Petitioner recorded the $175,000 Amoco advance on its books            
          as “Amoco/Deferred Income”.  Each month, petitioner reduced the             
          “Amoco/Deferred Income” account balance by  $1,458.33.  This                
          amount was determined by dividing $175,000 by 120 months.                   
          Petitioner did not record on its books any amount for interest              
          accruing on the Amoco advance.                                              
               Petitioner timely filed its Forms 1120, U.S. Corporation               
          Income Tax Return, for the taxable years 1996 and 1997.  On                 
          Schedule L, Balance Sheets per Books, attached to petitioner’s              
          1996 Form 1120, petitioner reported $164,792 of the Amoco advance           
          as a liability representing deferred income.  On the 1996 Form              
          1120, petitioner reported the credited $10,208 payment in                   
          connection with the Amoco advance as other income.  On the 1996             
          return, petitioner reported a 1996 net operating loss of $91,654            
          and a net operating loss carryover from 1995 of $38,317,                    
          resulting in a $129,971 net operating loss carryover to 1997.               
               On Schedule L, Balance Sheets per Books, attached to                   
          petitioner’s 1997 Form 1120, petitioner reported $147,292 of the            
          Amoco advance as a liability representing deferred income.  On              
          the 1997 Form 1120, petitioner reported the $17,500 credited                
          payment as other income and described the payment as                        
          miscellaneous income from the store.  On the 1997 return,                   
          petitioner reported taxable income of $28,963 before net                    
          operating loss deduction and a net operating loss carryover                 






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Last modified: May 25, 2011