Jerome J. and Beatrice A. Mack - Page 16

                                        -  -16                                           
               On October 3, 1991, respondent mailed a notice of deficiency           
          to petitioners for the taxable years 1987, 1988, and 1989.                  
          Respondent determined, regarding the issues still remaining for             
          decision for the year 1987, that petitioners' income should be              
          increased by the disallowance of the claimed bad debt deduction             
          of $70,000.  Respondent determined that petitioner realized                 
          forgiveness of indebtedness income in 1987 upon the payment of              
          the mortgage on the Third Street property in the amount of                  
          $69,815, and since petitioner had fully depreciated the property,           
          he had unreported ordinary income of $43,318.80; and that the               
          remaining $26,494 was capital gain income which petitioner failed           
          to report in 1987.                                                          
               Respondent determined that petitioner's self-employment                
          taxes for the years 1987, 1988, and 1989 were in the amounts of             
          $5,387, $6,205, and $3,234, respectively, based on the amounts of           
          fees the law partnership paid to him in those years under the               
          purchase agreement.1                                                        
               Respondent determined that petitioners were liable for                 
          additions to tax for negligence and substantial understatement of           
          tax as set forth above for each of the years 1987 and 1988.                 




          1  On brief respondent conceded that $2,235.80, $2,409.30,                  
          and $2,643.33 of the amounts she determined to be self-employment           
          income represented payments for health insurance of petitioner              
          and should not have been included in self-employment income.                




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