- 24 - the losses would result in rightful tax refunds. Petitioner’s mere lack of understanding of the legal or tax consequences pertaining to the claimed losses is insufficient, by itself, to afford petitioner relief from the resulting liability. Petitioner made several expenditures that were relatively “unusual or lavish” when compared to the Pierces’ past or normal spending patterns. After the receipt of the tax refunds, petitioner contributed $490,000 of capital to DDC. In addition, loans from shareholder balances on MCU’s yearend financial statements ranged from $414,200 to $705,200 during the period 1992 to 1998.7 DDC’s financial statements reflected a $310,000 note payable to the limited partner (petitioner) for its yearend financial statements for 1993 through 1998. Petitioner contends that the contributions of capital were from her savings. She also contends that the loan balances shown as due her on the books of MCU and DDC could be attributable to accumulated or accrued interest on existing loans and liability transactions other than loans. We find curious, however, petitioner’s contention that she had enough money in personal savings to fund these transactions. The only other source of petitioner’s income mentioned in the record (outside her involvement with Mary Catherine) was her position as a part-time dental assistant. More significantly, petitioner did not provide 7 Petitioner was the sole shareholder of MCU.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011