- 4 -
sustaining respondent's disallowance of the ordinary loss
reported on the partnership's 1986 return.
As a result of the entry of decision in docket No. 7530-93,
respondent issued a notice to petitioners stating that respondent
was changing petitioners' account for 1986 to reflect the
following: (1) Entry of an assessment for tax in the amount of
$6,054 reflecting the computational adjustment attributable to
the disallowance of petitioner's distributive share of the
ordinary loss reported by Irving & Co., and (2) entry of an
assessment in the amount of $8,692.79 for interest computed at
the increased rate prescribed in section 6621(c) due from
petitioners on the tax deficiency of $6,054. (The notice
indicates that the assessment in the amount of $6,054 was offset
by petitioners' advance payment of that amount on July 20, 1994.)
On October 2, 1995, respondent issued a so-called affected
items notice of deficiency to petitioners for 1986. In
particular, respondent determined that petitioners are liable for
an addition to tax under section 6653(a)(1)(A) in the amount of
$303, an addition to tax under section 6653(a)(1)(B) equal to 50
percent of the interest due on $6,054, and an addition to tax
under section 6661 in the amount of $1,514, attributable to the
tax deficiency arising from the disallowance of petitioner's
distributive share of Irving & Co. partnership items.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011