Homer N. Cummings - Page 3

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          the taxable years 1983, 1984, and 1985.  Ira N. Smith, the tax              
          matters partner for December Associates, invoked this Court's               
          jurisdiction by filing separate petitions for readjustment.  See            
          December Associates, Ira N. Smith, Tax Matters Partner v.                   
          Commissioner, docket Nos. 25083-89, 25087-89, and 16800-90.                 
               On March 16, 1994, this Court entered decisions in each of             
          the foregoing 3 dockets involving December Associates.  The                 
          decisions eliminated all income, deductions, and credits claimed            
          on December Associates' partnership returns for 1983, 1984, and             
          1985.  No appeals were taken, and the decisions became final on             
          June 14, 1994.  Secs. 7481(a), 7483.                                        
               Shortly thereafter, respondent made computational                      
          adjustments to petitioner's tax liability for 1983, 1984, and               
          1985 in order to reflect the disallowance of the losses that                
          petitioner had claimed from his investment in December                      
          Associates.  Sec. 6231(a)(6).  Specifically, respondent computed            
          petitioner's tax liability based upon the elimination of                    
          petitioner's distributive share of the December Associates'                 
          losses that petitioner reported in 1983, 1984, and 1985, as well            
          as the elimination of the related net operating losses (NOL's)              
          that petitioner carried forward from 1983 to 1984 and from 1984             
          to 1985.  Consistent with these computations, and within 1 year             
          of June 14, 1994, respondent assessed petitioner $9,284 in                  
          additional tax for 1984 and $1,399 in additional tax for 1985.              






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