Gerard and Audrey Kathleen Hennessey - Page 31




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          provided a summary of petitioners’ positions with respect to the            
          issues of the latest settlement proposal.  With respect to the              
          deferred income issue, Ms. Stephenson stated that this amount was           
          “the accumulation of royalties owed to inventors” and that ISOA,            
          Inc., was “merely a conduit for distributing these royalty                  
          payments to the inventors.”  Ms. Stephenson for the first time              
          also claimed that ISOA, Inc.’s 1995 return erroneously indicated            
          that the corporation was on the cash basis method of accounting.            
          In addition, Ms. Stephenson stated that ISOA, Inc., was an                  
          accrual basis taxpayer and that the proper accounting treatment             
          of the “deferred income” would have been “to recognize the                  
          royalty income when received and set up a corresponding payable             
          to the inventors for the same amount.”                                      
               By letter to Ms. Stephenson dated August 11, 2000, Appeals             
          Officer Medina rejected petitioners’ June 2000 settlement                   
          proposal.                                                                   
          III.  The Notice of Deficiency                                              
               On October 19, 2000, respondent issued to petitioners a                
          notice of deficiency for their 1993 through 1996 individual                 
          taxable years.  The notice of deficiency also included                      
          adjustments with respect to Beacon for the taxable years 1993               
          through 1996 and ISOA, Inc., for the taxable years 1995 and                 










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