James E. and Shirley S. Deas - Page 4




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         responsibilities.  The partnership continued to employ the                   
         services of a public accounting firm.                                        
              In September 1986, Dasco purchased approximately 6 acres of             
         undeveloped real property (the property) in Orange County,                   
         Florida, for $537,500.  The property was purchased with proceeds             
         from the sale of other property contributed to the partnership by            
         Segrest.  In October 1992, Dasco received $857,413 from the State            
         of Florida as a result of a condemnation sale of the property to             
         the State.  Dasco elected to defer recognition of the gain from              
         the condemnation sale according to the provisions of section 1033            
         and, therefore, did not report the gain on its U.S. Partnership              
         Return of Income (Form 1065) for 1992.                                       
              The partnership used the proceeds from the condemnation sale            
         to pay partnership debt.  In 1995, Segrest, in his role as in-               
         house bookkeeper, informed the partnership's public accountant               
         that the partnership had never purchased replacement property and            
         would therefore have to file an amended return for 1992.  The                
         amended return was prepared by the public accountant and was                 
         signed by Segrest.  In a Schedule K-1, Partner's Share of Income,            
         Credits, Deductions, Etc., which was attached to the 1992 amended            
         return, the partnership reported that petitioner's share of the              
         gain was $165,000.                                                           
              Petitioner knew that the property was sold as a result of               
         the condemnation, and that if the partnership did not purchase               






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