- 2 -
Respondent determined the following deficiencies and
addition to tax in petitioner’s Federal income taxes:
Addition to Tax
Year Deficiency I.R.C. � 6651(a)(1)
1998 $10,446
1999 $12,345 $3,089
2000 $ 1,661
After concessions by the parties, the issue for decision is
whether the monetary transfers that petitioner and her deceased
husband made to a corporation are capital contributions or bona
fide debts that are deductible as business bad debts under
section 166.2
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in El
Paso, Texas.
Petitioner, Jean I. Tedford, married J.C. Tedford (Mr.
Tedford) in 1964. They were married until Mr. Tedford’s death.
Throughout their marriage, Mr. Tedford and petitioner resided in
El Paso, Texas. Mr. Tedford was born on April 29, 1919.
Petitioner was born on July 27, 1929.
2 Petitioner concedes that she is liable for an addition to
tax under sec. 6651(a)(1) for 1999.
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