- 24 -
In 1994, ERG paid $13,500 to MVPC and $2,000 to Camp
Timberwolf. On their personal return, the Bensons claimed a
charitable contribution deduction of $33,374, which included
$2,000 to Camp Timberwolf and $18,000 to MVPC. ERG’s 1995 Form
1120 reflected charitable contribution carryovers of $102,646
from 1991, $13,200 from 1992, $1,984 from 1993, and $20,000 from
1994. The $20,000 shown as a carryover from 1994 included a
$10,000 contribution to MVPC and a $2,000 contribution to Boy
Scouts of America (Timberwolf).
(i) Rent Paid to NPI for Stanford and Lowell Plants
Throughout 1988-94, ERG occupied the Stanford plant which
was owned by NPI. In 1988, a commercial lease for the Stanford
plant was prepared but not executed. Similarly, in 1988, a
commercial lease for the Lowell plant was prepared but not
executed. The Lowell plant was used by Glendon/Aker.25 During
the period 1988-94, ERG paid monthly rent to NPI for both the
Stanford and Lowell plants.26 The parties stipulated that the
25Glendon testified that he did not pay rent to NPI during
the period July 1987 through December 1994.
26Burton testified that before the arbitrators’ final
decision in March 1999, he considered it ERG’s responsibility to
pay the rent for ERG’s research and development division, Aker
Industries. In the final arbitration decision, the arbitrators
decided that Glendon/Aker was liable to NPI for rent for the
period July 1, 1987, through Dec. 31, 1998, in an amount
including interest, totaling $420,650.
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