- 4 -
The adjustments raised by respondent in the notice of
deficiency, answer, and amendment to answer are as follows:
Tax Years Ended
Adjustments to Income 1982 1983 1984
a. Partnership fee income $624,000.00 $1,017,900.00 $291,700.00
ADJ/Bethel Woods, Ltd. -0- 153,900.00 -0-
ADJ/Bethel Woods, Ltd. -0- 3,222.00 -0-
b. Newtowne 131,014.00 1,282,500.00 -0-
Park Place -0- -0- 180,000.00
Saltergate I 120,000.00 -0- -0-
Cost savings -0- 106,037.66 202,028.76
Architectural fee -0- -0- 30,000.00
Ford Van 8,860.71 -0- -0-
c. Savko -0- 124,330.00 34,000.00
d. Interest -0- (10,524.00) -0-
e. Schedule C
Oil & gas exploration 3,484.00 -0- -0-
Uncollectible operating expense -0- -0- 2,516,224.00
Gross receipts -0- -0- (480,800.00)
Total 787,358.71 2,677,365.66 2,773,152.76
1 This amount reflects the difference between $158,000, as determined by respondent
in the notice of deficiency, and $126,986, as reported on petitioner's 1982 return.
After concessions,3 the issues for decision are: (1)
Whether petitioner failed to report income he received from
several partnerships on his 1982, 1983, and 1984 Federal income
tax returns; (2) whether petitioner received income from
Newtowne, Inc., which was not reported by petitioner on his 1982,
3 Respondent concedes the following issues raised in the
notices of deficiency and amendment to answer: (1) An increase
in taxable income for 1984 in the amount of $34,000 identified in
the amendment to answer as "a kickback from Savko"; (2) $1,060.71
of the Ford Van income raised in the amendment to answer for
1982; (3) $1,371.02 of the cost savings adjustment raised in the
amendment to answer for 1984; and (4) the addition to tax for
fraud under sec. 6653(b)(2) on that portion of the deficiencies
attributable to:
Year Adjustment Amount
1982 Schedule C - Oil and gas exploration $3,484
1983 Partnership fee income (AJD/Development. Co.) 65,650
1983 Partnership fee income (Savko) 124,330
1983 Partnership fee income (AJD/Bethel Woods, Ltd.) 3,222
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