- 2 - R asserted inconsistent income tax deficiencies with respect to P1, P2, and P3. R claimed that P1 owned the promissory notes until the time they were paid, meaning that only P1 is taxable on the note proceeds. In the alternative, R claimed that P1 gave P2 and P3 an interest in the joint venture at the time of its inception, meaning that only P2 and P3 are taxable on the note proceeds. R also imposed additions to tax under secs. 6653 and 6661(a), I.R.C., against all petitioners. 1. Held: P1 gave P2 and P3 certain rights under the earnest money contracts and is therefore not taxable on the note proceeds. 2. Held, further, P2 and P3 owned the notes at the time the notes were paid and are therefore taxable on the note proceeds. 3. Held, further, R’s imposition of additions to tax under secs. 6653 and 6661, I.R.C., is not sustained as to P1. 4. Held, further, because P2 and P3 failed to carry their burden of proof with respect to the additions to tax, R’s imposition of additions to tax under secs. 6653 and 6661, I.R.C., is sustained as to P2 and P3. Timothy O'Dowd and Edwin K. Hunter, for petitioners in docket Nos. 345-92 and 352-92. Robert I. White, Linda S. Paine, and William Grimsinger, for petitioners in docket No. 900-92. Stephen J. Davis, pro se in docket No. 352-92. William Bissell, Portia N. Rose, and David B. Mora, for respondent.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