- 3 - For the years at issue, 1999 and 2000, petitioner’s wages from the corporation were $20,200 and $15,600, respectively. On their joint Federal income tax returns for 1999 and 2000, these amounts were reported as income. However, in addition to his wages, petitioner also received from the corporation, generally on a weekly basis, payments that totaled $25,441 and $27,025, respectively, during 1999 and 2000. Over the years, petitioner received more than $150,000 in such payments beginning in 1995. The payments received in 1999 and 2000 were not included as income on petitioners’ income tax returns for these years. It is these payments that are at issue in this case. Petitioners contend these payments were gifts and, therefore, do not constitute gross income. Respondent determined otherwise in the notice of deficiency. For several years prior to 1999, the corporation experienced financial problems due largely to foreign competition. Mr. Marchisset had, from time to time, contributed additional moneys to keep the corporation afloat; however, over time, the corporation was unable to survive and ceased doing business in 2001. Before arriving at that point, however, in 1995, in an attempt to bolster the corporation’s finances and in order to pay petitioner a salary commensurate for his services, Mr. Marchisset made an additional infusion of capital to the corporation that was identified or maintained as a separate account on thePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011