- 28 - b. Petitioner Paul S. Mahoney Dr. Mahoney resided in Los Angeles, California, at the time he filed his petition in the instant cases. During 1981, he worked as a physician. Dr. Mahoney reported adjusted gross income of $175,155 on his 1981 Federal income tax return. On December 11, 1981, Dr. Mahoney subscribed to one partnership unit in JDP for a price of $50,000. As a result of his capital contribution to JDP, Dr. Mahoney acquired an 11.1- percent capital interest in JDP. Also on December 11, 1981, he executed the signature page to the certificate and agreement of limited partnership and certificate of fictitious name, offeree questionnaire, and a promissory note in the amount of $35,000 payable to JDP in installments of $15,000 on or before May 1, 1982, $10,000 on or before May 1, 1983, and $10,000 on or before May 1, 1984, together with interest of 10 percent per year of the unpaid balance. Dr. Mahoney paid to JDP or its escrow agent $15,000 on December 15, 1981, $16,160 on April 18, 1982, $12,000 on April 18, 1983, and $11,000 on May 1, 1984. On his 1981 Federal income tax return, Dr. Mahoney claimed a net loss relating to JDP of $40,529. By notice of deficiency dated June 21, 1989, respondent disallowed the partnership loss relating to JDP that Dr. Mahoney had claimed for 1981 on the grounds that he had not established: any amount was paid pursuant to a research and development agreement or, if paid, that such expenditures were not preconceived shams lacking economic substance.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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