- 5 -
in Schedule B, Other Information, line 6, "Does this partnership
have any foreign partners?". We conclude that the Partnership
had no foreign partners for either year.
The only partnership items reported on the Forms 1065 filed
in 1992 and 1993 were losses of the Partnership in the amounts of
$359,285.96 and $416,000, respectively.
Respondent issued a notice of deficiency to petitioner and
Elizabeth on March 20, 1996, for their 1992 and 1993 taxable
years. The principal adjustments to income as determined by
respondent in the notice of deficiency represent adjustments to
petitioner's allocable share of income from the Partnership in
1992 and 1993 in the amounts of $293,577 and $107,297,
respectively, and the inclusion in income of certain guaranteed
payments in 1992 and 1993 of $55,286 and $56,000, respectively,
all of which stemmed from respondent's disallowance of losses
attributable to the Partnership for those years during a related
partnership examination. Other adjustments to income were
computational in nature. In addition, respondent determined that
petitioner and Elizabeth were liable for accuracy-related
penalties for 1992 and 1993 pursuant to section 6662(a).
Petitioner filed his petition on June 27, 1996. On December
19, 1996, the Court issued a Notice Setting Case for Trial in
Washington, D.C. on May 19, 1997; attached thereto was a Standing
Pre-trial Order. The Notice states "YOUR FAILURE TO COOPERATE
MAY * * * RESULT IN DISMISSAL OF THE CASE AND ENTRY OF DECISION
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