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eBook details

• Title: Mts International Inc. v. Commissioner of Internal Revenue
• Author : Sixth Circuit U.S. Court of Appeals
• Release Date : January 04, 1999
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 75 KB

Description

Taxpayers MTS International and Robert C. Hughes, III appeal from a decision of the tax court finding that (1) a loss that Hughes sustained in connection with a stock sale was a capital loss rather than a theft loss for tax purposes, (2) withdrawals that Hughes made from MTS accounts were constructive dividends upon which he owed taxes, and (3) MTS was not entitled to deduct $196,672 for travel and entertainment expenses from its 1987 gross income. The taxpayers argue that a memorandum entered into between themselves and the government settled the dividend and entertainment expense issues, and that the trial court should have granted them further opportunity to prove this alleged settlement. For the reasons set forth below, we AFFIRM the tax courts judgment on all of the issues.

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