- 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 806,076Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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