- 31 - 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:Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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