Jack R. Prewitt and Shelley Prewitt - Page 2

                                        - 2 -                                         
          The 1980 through 1982 deficiencies are attributable solely to               
          respondent's determination that no investment tax or business               
          energy credits are allowable for the 1983 year, and hence, none             
          are available to carry back to 1980 through 1982.  The issues               
          remaining for our consideration are:  (1) Whether petitioners are           
          entitled to deduct various expenses paid by checks drawn on the             
          account of petitioner's S corporation; (2) whether $90,000 of               
          income received by petitioner in 1982 was repaid to a related               
          corporation during 1983, and if any amount was repaid, whether it           
          results in a deduction for petitioners; (3) whether petitioners             
          are liable for additions to tax for fraud under section 6653(b);1           
          and (4) whether the periods for assessment of income taxes had              
          expired before the notice of deficiency was issued.                         
                                  FINDINGS OF FACT2                                   
               Petitioners resided in St. Petersburg, Florida, at the time            
          their petition was filed.3  Petitioners filed joint Federal                 
          income tax returns and amended returns on the following dates:              
               Year      Original Filed      Amended Filed                            
               1980      Mar. 25, 1983       Dec. 4, 1985                             
               1981      Mar. 25, 1983       Dec. 4, 1985                             
               1982      Mar. 10, 1984       Dec. 4, 1985                             
               1983      June 23, 1984       Dec. 4, 1985                             


               1 Section references are to the Internal Revenue Code in               
          effect for the taxable years under consideration.  Rule                     
          references are to this Court's Rules of Practice and Procedure.             
               2 The parties' stipulation of facts and the attached                   
          exhibits are incorporated by this reference.                                
               3 Jack R. Prewitt maintained his residence in St.                      
          Petersburg, Florida, but at the time the petition was filed, he             
          was incarcerated in the Federal Prison Camp located on Tyndall              
          Air Force Base, which is situated in the State of Florida.                  

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011