Hubert Enterprises, Inc. and Subsidiaries v. Commissioner

125 T.C. No. 6

UNITED STATES TAX COURT HUBERT ENTERPRISES, INC. AND SUBSIDIARIES, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4366-03, 10669-03, Filed September 21, 2005. 16798-03. A few individuals controlled a corporation (P1) and a limited liability company (ALSL). P1 transferred $2,440,684.38 to ALSL primarily to retransfer to a related limited partnership for use in the construction of a retirement community. The construction project was discontinued, and $2,397,266.32 of the transferred funds has not been repaid. P1 seeks to deduct those unrecovered…