T.C. Memo. 2005-233
UNITED STATES TAX COURT
KARNS PRIME & FANCY FOOD, LTD., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 906-04. Filed October 5, 2005.
John D. Sheridan and Steven J. Schiffman, for petitioner.
Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$486,355 in petitioner’s Federal income tax (tax) for the taxable
year ended January 30, 2000 (year at issue).
The only issue for decision is whether the $1.5 million
($1.5 million at issue) that petitioner received from its princi-
pal supplier during the year at issue constitutes a loan that is
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