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Dornbrock claimed a Schedule E partnership loss and an investment
tax credit on their joint 1981 Federal income tax return from the
Pop Phonomasters program. They also filed amended joint Federal
income tax returns for 1978, 1979, and 1980, claiming investment
tax credit carrybacks for those years arising out of the Pop
Phonomasters program. The investment tax credits resulted in
Federal income tax refunds for each of these years. On April 12,
1985, a notice of deficiency was issued to Roger W. Dornbrock and
Maryn J. Dornbrock, husband and wife, for all years involving the
Pop Phonomasters program. In the notice of deficiency,
respondent determined the following deficiencies in Federal
income taxes and additions to tax:
Additions to Tax
Sec. Sec.
Year Deficiency 6653(a) 6659
1978 $3,273.50 $163.68 $982.05
1979 9,818.00 490.90 2,945.40
1980 3,081.00 154.05 924.30
These deficiencies arose solely from Roger W. Dornbrock's
participation in the Pop Phonomasters program.4
On July 11, 1985, a joint petition was filed on behalf of
approximately 35 petitioners who received notices of deficiency
as a result of their participation in the Pop Phonomasters
4
Although adjustments were made in the notice of deficiency
to the Dornbrocks' income for 1981, no deficiency was determined
for that year.
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