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3. The Deficiencies
(a) Unreported Income From the Partnerships
In the notice of deficiency, respondent determined that
petitioner failed to report fee income in the amounts of
$624,000, $1,252,600, and $57,000 on his 1982, 1983, and 1984
returns, respectively. Respondent also determined that
petitioner had overstated his 1983 interest income by $10,524 and
decreased that item accordingly. Respondent further determined
that petitioner's distributive share of partnership loss from
ADJ/Bethel Woods, Ltd., for 1983 was $56, and not $3,278 as
reported on petitioner's return. Since these matters were
determined in the notice of deficiency, petitioner bears the
burden of proof.
In her amendment to answer, respondent decreased her
determination with respect to petitioner's 1983 partnership fee
income by $234,700, and increased her determination with respect
to 1984 partnership fee income by an equal amount. Respondent
also asserts that petitioner failed to report additional
partnership fee income in the amount of $153,900 in 1983.
Respondent bears the burden of proof with respect to the
increased deficiencies. Rule 142(a).
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