-172-
Exh. 93, at 10; Exh. 114, at 6-7; Petitioners’ Reply Brief at
524-525. When IRA distributed its Sherwood Partnership interest
to Carlco, TMT, and BWK in 1984, IRA reported a gain of $51,744
on the distribution (apparently representing the difference
between IRA’s capital contributions of $325,000 and partnership
losses totaling $376,742 that IRA reported for 1982 and 1983).
Exh. 19, at 5 of 25.
In 1985, IRA reported a long-term capital loss of $46,925
attributable to the sale of a note receivable from Sherwood.
Exh. 20, at 5. IRA reported that it acquired the note receivable
in October 1984 and sold the note for $1,000 on December 1, 1985.
Id. Neither IRA’s general ledger nor its trial balance ledger
for 1984 reflects the acquisition of a Sherwood promissory note.
(iv). Accounting Treatment
Carlco, TMT, and BWK recorded IRA’s cash distributions as
capital contributions, and they recorded IRA’s transfers of its
Essex and Sherwood partnership interests as paid-in capital, as
follows:
Page: Previous 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 NextLast modified: May 25, 2011