- 41 - The financial statement that was part of Cap Corp.’s 1996 Federal return reflects that Cap Corp.’s assets were just under $151,000 and its liabilities were well over $4 million. Cap Corp.’s 1996 return also reflected a net loss of $641,600 for Cap Corp. and its subsidiaries. As of November 30, 1997, Cap Corp. owed petitioner $1,859,135, consisting of the $500,000 outstanding debt along with $1.257 million of additional advances made during 1997, plus interest. During 1997, petitioner made advances to Cap Corp. of $55,000 on January 31, 1997; $50,000 on April 30, 1997; and $1.152 million on July 31, 1997. Cap Corp. (through Koehler) issued petitioner a December 1, 1996, promissory note to cover the above debt. Among other things, Cap Corp. promised to pay on or before November 30, 1997, all outstanding principal and 10 percent interest to petitioner. E. Petitioner’s 1997 Ordinary Loss and Bad Debt Deduction; Petitioner’s 1998 AeroCentury Stock Transaction On its 1997 return, petitioner claimed a $1,859,135 bad debt deduction consisting of: (1) The $500,000 Cap Corp. debt not assumed by CKH in the debt conversion transaction; (2) the $1,257,000 of advances to Cap Corp. during 1997; and (3) $102,135 of interest owed petitioner by Cap Corp. Petitioner did not claim a deduction with respect to CKH’s $2.259 million assumption of Cap Corp.’s debt or the conversion of the Cap Corp. debt intoPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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