- 12 -
petitioner by the partnership during 1988, including the Form
1099 issued with respect to the $190,000 payment made by the
partnership to petitioner during 1987. Mr. Abelson spoke with
Mr. Beane concerning the matter, and, as result of their
conversations, Mr. Abelson believed that (1) the payment
represented the repayment of a loan by petitioner to the
partnership, (2) the Form 1099 had been issued in error, and (3)
the payment should not be reported as income to petitioner. Mr.
Abelson did not ask petitioner whether he had loaned money to the
partnership. Consequently, petitioner did not report the
$190,000 he received from the partnership during 1987 as income
during 1987 or any other year on petitioners’ Federal income tax
returns.
During the audit of petitioners’ 1987 Federal income tax
return, Mr. Abelson was asked by the examining agent for an
explanation of, inter alia, the Form 1099 for $190,000. Mr.
Abelson contacted Mr. Beane for information, and following some
discussion and an exchange of letters, Mr. Abelson came to
believe that the $190,000 represented management fees that had
accrued to petitioner from 1983 through 1986.
At the time respondent issued the statutory notice of
deficiency in the instant case, additional assessments of taxes
for petitioners’ 1983 through 1986 Federal income tax years were
barred by the statute of limitations.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011