Holden C. Gutermuth - Page 4

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          $39,000 to the bank account of NTG.  This $39,000 represented               
          liquidating distributions due petitioner and Mr. Troue with                 
          regard to their former partnership interests in NTGO.  Of the               
          $39,000 NTGO transferred to NTG, $15,000 was attributable to                
          petitioner's former interest in NTGO.                                       
               For 1989, Mr. Troue filed with respondent a Form 941                   
          (Federal Employment Tax Return) with respect to NTG.  On the Form           
          941, Mr. Troue represented that NTG constituted a partnership.              
               On March 30, 1990, due to disagreement over management of              
          the law firm, petitioner and Mr. Troue ceased doing business                
          together and terminated NTG.                                                
               On his individual 1989 Federal income tax return, petitioner           
          reported his interest in a number of partnerships including NTG,            
          and petitioner claimed a $35,000 partnership loss deduction                 
          relating to NTG.                                                            
               On audit of petitioner’s individual 1989 Federal income tax            
          return, respondent disallowed a number of deductions with respect           
          to petitioner’s real estate business and the claimed $35,000                
          partnership loss deduction relating to NTG.  Prior to trial,                
          petitioner and respondent settled all of the adjustments                    
          respondent made to petitioner's individual 1989 Federal income              
          tax return except for the disallowed $35,000 partnership loss               
          deduction and the negligence penalty.                                       








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