- 5 - History of the Consolidated Cases By notices of deficiency dated December 29 and 31, 2000 (the notices of deficiency), respondent determined deficiencies in the Federal income taxes of petitioners for the audit years. Explanations included with the notices of deficiency show adjustments to petitioners’ incomes resulting from changes in the treatment of items of ACC passed through to Blasius and Balan on account of their status as shareholders of ACC. Respondent required the capitalization of certain costs incurred (and deducted) by ACC in connection with (1) “Loan Origination/ Acquisition”, (2) “Offering Expenses”, and (3) “Professional Fees”. On March 30, 2001, petitions were filed in the cases (the petitions), and, on May 21, 2001, respondent answered the petitions denying all assignments of error. On January 9, 2002, the Court notified the parties that the cases were set for trial at the trial session of the Court commencing June 10, 2002, in Detroit, Michigan. On March 14, 2002, attorney Oksana O. Xenos, on behalf of all petitioners, wrote a letter to Eric R. Skinner, one of respondent’s counsel in this case. In that letter, Ms. Xenos requested that, in light of respondent’s position regarding the deductibility of the types of costs at issue in the consolidated cases, as stated in Announcement 2002-9, 2002-1 C.B. 536, issuedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011