Timothy Dean Strong - Page 20

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          553 F.2d 94 (2d Cir. 1977).  SCC was a valid Minnesota                      
          corporation.  More critical to this question, SCC was engaged in            
          the construction business and houses were sold in its name during           
          the years in question.  SCC was jointly listed with Mr. Strong on           
          account No. 893315300 where the receipts in dispute were                    
          deposited.  Checks for house sales were issued with SCC as the              
          payee.  Mr. Strong chose to operate the construction business               
          through a corporation, not a sole proprietorship.  Under these              
          facts, SCC must be recognized as a distinct taxable entity.                 
          II. SCC’s Unreported Income and Expenses                                    
               The extent of SCC’s taxable income is a separate issue.                
          There are two distinct questions in this regard.  First, should             
          the unreported deposits be treated as income, and second, should            
          SCC be allowed deductions against its income in addition to those           
          allowed by respondent?                                                      
               A.   Construction Income                                               
               The parties stipulated that the construction business earned           
          gross income of $264,800 in 1990, $524,720 in 1991, $531,900 in             
          1992, $85,448 in 1993, and $531,396 in 1994 from the construction           
          and sale of houses.  This business was conducted in SCC’s name,             
          and the deposits of proceeds from these home sales should be                
          included in SCC’s gross income.                                             









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