- 14 -
Petitioners reported no distributive share of gain to petitioner
from Pecaris in respect of the Mall transaction on their 1988
Form 1040. Petitioners attached Form 8082 (Notice of
Inconsistent Treatment or Amended Return) to their 1988 Form
1040, disclosing that petitioner was taking a position
inconsistent with the Schedule K-1 filed by Pecaris.
Petitioners' Form 8082 showed a reduction to zero in the amount
of the Pecaris reported section 1231 gain of $827,968 attributed
to petitioner and provided the following explanation: "Traded up
Real Estate Interests in Like-Kind Exchange." Petitioners' Form
8082 did not disclose that the $100,000 real estate brokerage
commission used by Pecaris as an offset in computing its gain on
10(...continued)
Buildings and other
depreciable assets $3,459,502 Partners' capital (182,469)
Minus depreciation 113,936 3,345,566
Land 458,845
Other assets 33,345 _________
Total liabilities
Total assets 3,990,801 and capital 3,990,801
Schedule M - Reconciliation of Partners' Capital Accounts
Capital
beginning of Capital Capital
year contributed Income Withdrawals end of year
Petitioner - 0 - - 0 - $7,450 $258,399 ($250,949)
Giorgi - 0 - $76,251 329 8,100 68,480
Total - 0 - 76,251 7,779 266,499 (182,469)
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011