15
Year 1990 1991 1992
Ordinary income/(loss) per Corp.
Return ($148,582) ($39,713) $54,188
Adjustments to income and expenses
a. Deferred income - customers dep. 1,505,102 (1,699) 13,634
b. Depreciation 3,178 6,975 --
c. Advertising 31,841 13,097 --
Ordinary income/(loss) as determined 1,391,539 (21,340) 67,822
Applicable ownership interest 100% 100% 100%
Your distributive share 1,391,539 (21,340) 67,822
Ordinary income/(loss) as reported (148,582) (39,713) 54,188
Increase (decrease) 1,540,121 18,373 13,634
Respondent's retained copy of the last two pages of the
notice of deficiency contained an alternative tax computation for
tax years 1991 and 1992 (exhibit B of the notice) and a
computation of the accuracy-related penalty for negligence and
substantial understatement of income tax under section 6662(c)
and (d) for tax years 1990, 1991, and 1992 (exhibit C of the
notice). Respondent did not mail those two pages to petitioner.
In summary, the notice of deficiency stated: (1) That
respondent had examined Eagle's tax returns; (2) that respondent
had furnished a detailed report to Eagle's tax matters partner or
person; and (3) for 1990, 1991, and 1992, (a) how much ordinary
income and loss and customer deposit income respondent determined
Eagle had, and (b) the amount of tax respondent determined
petitioner owed.
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