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$9,741 for 1991, and $4,354 for 1992, and accuracy-related
penalties of $86,741 for 1990, $1,948 for 1991, and $871 for 1992
under section 6662. Respondent determined that petitioner's
distributive share of ordinary income from Eagle for 1990, 1991,
and 1992 should be increased. The notice of deficiency stated as
follows:
It is determined that your distributable share of
ordinary income from the small business corporation
known as "Eagles Nest Homes" is $1,391,539 and $67,822
for the taxable years ended December 31, 1990 and 1992
and your distributable share of ordinary loss is
$21,340 for the taxable year ended December 31, 1991
rather than the loss amounts of $148,582 and $39,713
for the taxable years ended December 31, 1990 and 1991
and the amount of $54,188 for the taxable year ended
December 31, 1992 as was claimed on your returns for
those taxable years. This determination is based on an
examination of the corporate return of "Eagles Nest
Homes" for the taxable years ended December 31, 1990,
1991 and 1992, which is summarized below. A detailed
report has been furnished to the tax matters partner
(person) who should be contacted for additional
information. Accordingly, your taxable income for the
taxable years ended December 31, 1990, 1991 and 1992 is
increased by the respective amounts of $1,540,121,
$18,373 and $13,634.
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