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