- 9 -
Plotkin v. Commissioner, T.C. Memo. 2001-71; Estate of Gray v.
Commissioner, T.C. Memo. 1995-421.
Mr. Molina stopped making monthly payments on the 1998 loan
in March 1999. Additionally, the city no longer required monthly
installment payments on the 1998 loan, and had no provision for
Mr. Molina to continue making monthly installment payments on the
1998 loan, after Mr. Molina’s termination. Thus, after March
1999, the 1998 loan was no longer required to be repaid by means
of level amortization. See sec. 72(p)(2)(C). Accordingly,
pursuant to section 72(p), no distribution includable in Mr.
Molina’s gross income occurred in 2000.
It is unclear from the record, however, whether, after
application of our holding that petitioners did not have to
report the $19,620 deemed distribution in 2000, petitioners’ tax
liability for 2000 remains unpaid. Accordingly, we will direct
the parties to submit computations showing the correct amount of
petitioners’ tax liability for 2000.
To reflect the foregoing,
An appropriate order
will be issued.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011