- 4 - $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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011