- 5 - section 6662(a) because of negligence or disregard of the rules or regulations. As a defense to respondent’s determination of omitted income, petitioners seek to characterize the $32,500 check issued to OTFP by Ms. Johnson as a loan. Petitioner and Ms. Johnson did not execute a loan agreement with respect to the $32,500 payment. Petitioner testified about the payment from Ms. Johnson. He indicated that it “was a personal loan made from Ms. Jill Johnson to myself” and because it “was sealed with a hug and a handshake outside of her –- outside of our Summer League offices in West L.A., and if that was good enough for her, that was good enough for me.” According to petitioner, Ms. Johnson, a personal friend, lent petitioner the money because he agreed to produce the FSZ show. OTFP used the $32,500 payment to: (1) Produce the FSZ show; (2) to pay expenses on other projects; and (3) for general office expenses. Petitioner deposited the check into the business bank account of OTFP. Petitioner testified that he did not have the funds available to produce the FSZ show and required funds from Ms. Johnson because he was in bankruptcy at the time. Petitioner produced a letter dated December 21, 1999, from Ms. Johnson which indicated that she lent petitioner funds to assist in the operations of OTFP.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011