Albert J. and Helen R. Desantis - Page 31

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          Colony II, Building 9, Ltd.  Petitioner deducted $28,000 for                
          worthless debts owed him by that partnership on his 1984 return.            
               In the notice of deficiency, respondent disallowed the                 
          claimed bad debt.  Also in the notice of deficiency, respondent             
          decreased reported income by $1,933,600.  The basis for the                 
          adjustment was that petitioner incorrectly reported fee income in           
          1984 that should have been reported in other years.  In the                 
          amendment to answer and on brief, however, respondent asserts               
          that reported income for 1984 should have been reduced by                   
          $480,800, rather than the $1,933,600 determined in the notice of            
          deficiency.  Therefore, as a result of her amendment to answer,             
          respondent's claimed adjustment with respect to Schedule C of the           
          1984 return is $2,035,424, rather than $582,624 as originally               
          determined.                                                                 
               In her amendment to answer, respondent reduced the 1984                
          reported consulting fee income by $480,800 and specifically                 
          identified the amounts of payments from named partnerships                  
          controlled by petitioner.  The following fee income was reported            
          on the 1984 return; however, respondent contends that it properly           
          belongs on the 1982 and 1983 returns and was so determined in the           
          notice of deficiency:                                                       










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