Indeck Energy Services, Inc., and Subsidiaries - Page 2




                                        - 2 -                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GALE, Judge:  By separate notices of deficiency, respondent            
          determined the following deficiencies and penalties with respect            
          to petitioners' Federal income taxes:                                       
                    Indeck Energy Services, Inc. and Subsidiaries                     
                       docket No. 21586-97                                            
                                                       Penalty                        
               Year                Deficiency          Sec. 6662(a)                   
               FYE 11/30/93        $1,542,339          $231,108                       
               FYE 11/30/94        4,994,929           999,468                        
               FYE 11/30/95        536,715             107,343                        

                             Michael P. and Maya Polsky                               
                              docket No. 23943-97                                     
                                                       Penalty                        
                    Year           Deficiency          Sec. 6662(a)                   
               CY 1994             $660,910            $132,182                       
               These cases were consolidated for trial, briefing, and                 
          opinion.  After concessions, we must decide the following issues:           
               (1)  Whether $4,856,922 of a $19,886,922 settlement payment            
          made by petitioner Indeck Energy Services, Inc. (Indeck), to                
          petitioner Michael P. Polsky (Mr. Polsky) on May 16, 1994,                  
          constitutes interest deductible by Indeck and recognizable as               
          ordinary income by petitioners Michael P. and Maya Polsky in                
          their respective taxable years ended in 1994, or instead is part            
          of the purchase price for shares of Indeck stock sold by Mr.                
          Polsky to Indeck; and                                                       






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011