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received from Savko on his 1983 and 1984 returns, respectively.
Respondent conceded $34,000 of income from Savko with respect to
1984.
5. Schedule C Oil and Gas income
One of the Schedules C of petitioner's 1982 return reflects
that petitioner, doing business as "Albert J. DeSantis", engaged
in "Oil & Gas Exploration". Petitioner claimed a deduction for
windfall profits tax withheld in 1982 in the amount of $3,484.
In the notice of deficiency, respondent disallowed the deduction
of windfall profits tax withheld in 1982 and increased
petitioner's 1982 taxable income by $3,484.
6. Uncollectible Operating Expenses
On Schedule C of his 1984 return, petitioner reported
$2,742,409 in gross receipts or sales. Petitioner also claimed a
bad debt deduction in the amount of $2,516,224, attributable to
his financial consulting activity, as "Uncollectible operating
advances". Meeks advised petitioner that in order to claim the
bad debt deduction, petitioner was required to file amended
partnership returns to reflect this discharge of indebtedness
income. Petitioner did not heed this advice despite Meeks'
insistence on making these changes. The only partnership that
reported discharge of indebtedness income during 1984 was Bethel
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