- 5 -
partner. On his Form 1040 for 1984, petitioner deducted $141,233
attributable to Data Flex.
The principal place of business for each of the partnerships
was DiRicco’s office in San Mateo, California. DiRicco formed,
organized, promoted, and served as the TMP for Synergistics,
Lumenetics, and Data Flex.
Synergistics filed a tax return for 1982, which was
processed by the IRS on or about October 19, 1983. Synergistics
was audited for 1982 under the TEFRA audit procedures. A waiver
had been signed extending the period of limitations for
assessment of Synergistics to August 4, 1996. Lumenetics filed a
tax return for 1983. Lumenetics was audited for 1983 under the
TEFRA audit procedures. Data Flex filed a tax return for 1984.
Data Flex was audited for 1984 under the TEFRA audit procedures.
By notice of final partnership administrative adjustment
(FPAA) mailed to the TMP, dated October 1, 1987, respondent
disallowed a deduction that was reported on the Lumenetics 1983
tax return as “marketing expenses”. In response to the FPAA,
DiRicco filed a petition with the Court on January 4, 1988, at
docket No. 114-88. DiRicco also filed petitions with the Court
for Synergistics and Data Flex at docket Nos. 24781-87 and
20257-90, respectively. DiRicco stipulated, on behalf of
Synergistics and Data Flex, that certain TEFRA issues in their
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011