Newman v. Quinn

558 F. Supp. 1035, 19 V.I. 459, 52 A.F.T.R.2d (RIA) 5570, 1983 U.S. Dist. LEXIS 19292
CourtDistrict Court, Virgin Islands
DecidedFebruary 14, 1983
DocketCivil No. 1981-214
StatusPublished

This text of 558 F. Supp. 1035 (Newman v. Quinn) is published on Counsel Stack Legal Research, covering District Court, Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Newman v. Quinn, 558 F. Supp. 1035, 19 V.I. 459, 52 A.F.T.R.2d (RIA) 5570, 1983 U.S. Dist. LEXIS 19292 (vid 1983).

Opinion

O’BRIEN, Judge

MEMORANDUM OPINION

Petitioners filed a joint income tax return for the calendar year 1976 with the Commissioner of Finance, now known as the Director of the V.I. Bureau of Internal Revenue. On their 1976 income tax return, petitioners claimed business bad debt losses from monetary advances to Tropical Motors Corporation totaling over $110,000. A timely statutory notice was sent to petitioners notifying them of an income deficiency based in part on disallowance of the aforesaid business bad debt loss deduction. Petitioners timely filed a redetermination of this alleged deficiency, pursuant to 33 V.I.C. § 943 and the case was tried before this Court without a jury on November 18, 1982.

The Court is called on in this case to decide whether certain advances made by petitioner Warren S. Newman (“Newman”) to Tropical Motors Corporation, a corporation largely owned by him, should be classified as loans or as contributions to capital under the Internal Revenue Code.1 Since the corporation became defunct and [461]*461the money was never repaid, Newman would be entitled to deduct the lost advances against income if the transactions are treated as loans. If they are contributions to capital, they are deductible only as capital losses to offset capital gains, if any. The Court finds that some of the advances are loans, and others are contributions to capital, all for the reasons cited herein.

I. FACTS

In March 1971, Newman became the controlling shareholder of Tropical Motors Corporation (“TMC”), an automobile dealership. That transaction, while it did not involve an immediate cash outlay by Newman, consisted of Newman guarantying certain loans for the corporation. It was through his efforts that an extension of a line of credit from a bank was acquired for TMC. At the time of Newman’s takeover, TMC had more liabilities, which included outstanding loans, than assets. The principal of the loan which Newman first guarantied was reduced by agreement to an amount sufficient to balance the assets and liabilities. Newman concedes that, under this arrangement, with assets and liabilities equally balanced, there was no shareholder’s equity in the corporation.

Here is the profit picture of the corporation at the end of the corporation’s fiscal year, August 31, for the years that Newman controlled it:

Aug. 31,1971 $ 27,544 profit
Aug. 31,1972 47,023 profit
Aug. 31,1973 67,531 profit
Aug. 31,1974 (143,833) loss
Aug. 31,1975 (62,970) loss

While the picture for the fiscal year ending August 31, 1973, appears to reflect the largest profit of the first three years of the company while under Newman’s control, a closer analysis of the corporation’s financial position demonstrates that it was headed for trouble, a position which will be later described in this opinion.

A. NEWMAN’S ADVANCES TO TMC

After Newman acquired the shares of TMC in March 1971 with no cash investment, he made a series of advances to TMC. The following is a table indicating each of the notes he claims was issued for the advances, the dates issued, the due date, and the interest each note should have earned from the date of issuance to the end of 1975:

[462]*462Table No. 1

NOTES AND INTEREST EARNED

None of these notes were ever paid. As each fell due it was not paid, and there is no convincing evidence that there was any formal extension of the due date of any of them. Some of them were due and outstanding when subsequent advances were made. There was also a $5,000 one year note issued in January 1973, which was not paid until August 1975, about 20 months after it became due. This note, since it was ultimately paid, is not listed in the above table. These notes that were issued but never paid should have earned Newman $21,399.98 in interest from their respective dates of issuance through the end of 1975.2

Newman’s tax returns for the same period give us the picture of what interest actually was paid on these notes. Here is what the tax returns show:

Table No. 2

INTEREST ACTUALLY PAID ON NOTES

Year Amount
1971 $ — 0—
1972 2,089
1973 Unknown
1974 6,800
1975 2,150
1976 —0—

This amount would include any interest paid on the $5,000 note that actually was paid off. It can reasonably be seen that the notes, although no principal was being paid, were nearly current as to [463]*463interest through the end of 1974. No interest of any kind was paid in 1975, although $8,800.24 was due to be paid. See Table No. 1.

B. TMC’S ONGOING FINANCIAL CONDITION

When Newman acquired TMC’s shares of stock, as stated earlier, he did not put up any cash. As of March 1, 1971, the date he took over the business, there was $81,610 cash on hand. Six months later, by the end of that fiscal year, August 31, 1971, the cash on hand had dropped to $52,939, to which Newman had already advanced $20,000.

Never again was the corporation to have as much cash on hand for day-to-day operations as it had had on the day Newman took over the business. The following table demonstrates a comparison of the cash on hand for operating expenses against the advances made by Newman:

Table No. 3

Comparison-CASH ON HAND TO ADVANCES MADE

As of 2/28/71 $81,610
8/31/71 52,939 ($20,000 advanced by Newman)
8/31/72 79,647 (No advances during fiscal year by Newman)
8/31/73 60,530 ($35,000 advanced by Newman; $55,000 now owed to Newman)
8/31/74 54,183 ($40,000 advanced by Newman; $95,000 now owed to Newman)
8/31/75 51,817 ($16,516 advanced by Newman; $111,516 now owed to Newman)

By August 31,1973, as the table indicates, TMC had $60,530 cash on hand and owed Newman $55,000. During the fiscal year ending August 31, 1974, Newman advanced another $40,000, making a total of advances of $95,000. The corporation, however, ended that fiscal year with only $54,183 cash. Thus, after August 31, 1973, the corporation would never have been able to simply pay off Newman out of the cash on hand.

The corporation was always suffering from liquidity problems, but this became especially severe during the fiscal year ending August 31, 1973, for a variety of reasons. On paper, the corporation ended that fiscal year with a profit of $67,531, its best performance under Newman’s ownership. But as stated earlier, danger signals emerged during that fiscal year, and those danger signals can be linked, at least in part, to a vast increase in the inventory of unsold new cars which sapped the corporation of its financial strength beginning in late 1972. The following table shows that the year-end [464]

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Cite This Page — Counsel Stack

Bluebook (online)
558 F. Supp. 1035, 19 V.I. 459, 52 A.F.T.R.2d (RIA) 5570, 1983 U.S. Dist. LEXIS 19292, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newman-v-quinn-vid-1983.