- 3 - During 1982, petitioners formed a second S corporation named Gilliflower’s Shoppe Steinway Street, Ltd. (GF II). In October 1982, GF II opened a 3,500-square-foot retail store in Astoria, New York. This store operated at a loss in 1982 and closed in July 1984. GF II later opened two other stores. The record does not establish the income or loss of GF II for any of its taxable years. Nor does the record establish the amount of the income or loss of GF II that passed through to petitioners. On June 23, 1983, petitioners filed a chapter 11 petition in the name of GF II in the United States Bankruptcy Court for the Eastern District of New York.1 On the same date, they filed in the same court a chapter 11 petition in their own names. On April 5, 1984, they filed in that court a chapter 11 petition in the name of GF I.2 All three proceedings were converted to chapter 7 proceedings on November 16, 1984, and each of these proceedings was closed in or about 1987. Petitioners reported on their 1988 through 1997 Federal income tax returns the following negative amounts of adjusted gross income: 1 At the time of this filing, petitioners each owned 50 percent of the stock of GF II. Also at that time, GF II reported in its filings that its assets and liabilities on June 20, 1983, totaled $722,850 and $448,640, respectively. 2 At the time of this filing, petitioners were the sole shareholders of GF I.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011