Kamil F. and Nagwa Gowni - Page 26

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                    1.  Disallowance of Long-Term Capital Loss Carryover              
               The long-term capital loss carryover of $42,000 that was               
          reported on the Gownis’ 1999 return was disallowed because it               
          resulted from their reporting a capital loss rather than a                  
          capital gain from the transaction between Tomson and Sembler on             
          their 1998 return.  The IRS adjusted the Gownis’ income to                  
          account for this disallowance.                                              
                    2.  Corporate Distributions                                       
               The Gownis received and deposited into their personal bank             
          accounts checks from Tomson, net of repayments, totaling $50,610.           
          The IRS determined that Tomson was an S corporation during 1999             
          and that these distributions were made from sources other than              
          the proceeds of the transaction between Tomson and Sembler.                 
          Therefore, the IRS determined that the Gownis should have                   
          included this amount in income.                                             
               The Gownis received and deposited into their personal bank             
          accounts checks from Mina of Forest City, net of repayments,                
          totaling $63,277.  The IRS determined that Mina of Forest City              
          was an S corporation during 1999.  Accordingly, the IRS                     
          determined the net taxable distribution that the Gownis received            
          from Mina of Forest City by reducing this $63,277 amount by                 
          one-half of the ending balance of the accumulated adjustments               
          account reported on Mina of Forest City’s Form 1120S filed for              








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