- 40 -
Petitioner's final argument, that the payments represent
loans from the partnerships to petitioner, is also without merit.
There is no evidence in the record which indicates that such
loans were made. In addition, the offering circulars for the
limited partnerships clearly prohibit the making of such loans to
petitioner, the general partner.
We hold that petitioner failed to report fee income in the
total amounts of $624,000, $806,076,8 and $273,700, on the 1982,
1983, and 1984 returns, respectively.
(b) Unreported Income From Newtowne and Related
Transactions
In the notice of deficiency, respondent determined that
petitioner failed to report income he received from Newtowne in
the amounts of $31,014 and $1,282,500 on his 1982 and 1983
returns, respectively. Petitioner has the burden of proof with
respect to these adjustments.
In her amendment to answer, respondent claims that
petitioner failed to report income he received from Newtowne and
from transactions with Newtowne in the amounts of $8,860.71,
8 Calculated as follows:
Amount received less concession $816,600
Less interest conceded (10,524)
1983 omitted fee income 806,076
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