Sarunas Abraitis - Page 2

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                  Respondent determined a deficiency in petitioner's Federal                             
            income tax for 1993 in the amount of $1,055 and an accuracy-                                 
            related penalty pursuant to section 6662(a) in the amount of                                 
            $211.                                                                                        
                  After concessions by respondent,2 the issue remaining for                              
            decision is whether petitioner is entitled to a credit or refund                             
            for an overpayment of his 1993 Federal income tax.                                           
                  Some of the facts have been stipulated and are so found.                               
            The stipulations of fact and attached exhibits are incorporated                              
            herein by this reference.  Petitioner resided in Cleveland, Ohio,                            
            on the date the petition was filed in this case.  Petitioner                                 
            resided in Spring, Texas, on the date his amended petition was                               
            filed.                                                                                       
                  On March 30, 1993, and April 16, 1993, petitioner made two                             
            payments in the amount of $12,500 each to American Wireless                                  
            Systems, Inc. (AWS), which was promoting investments in the                                  
            emerging wireless cable television industry.  The $25,000 was                                
            used to purchase, on petitioner's behalf, four units in a                                    
            partnership called Wireless Cable TV Associates #38 (WCTVA).                                 
            Petitioner thereby became a general partner in WCTVA.                                        



            2           Respondent concedes all of the adjustments determined                            
            in the statutory notice of deficiency.  In addition, the section                             
            6662(a) accuracy-related penalty is not applicable because                                   
            respondent's concessions eliminate any underpayment of tax for                               
            petitioner's 1993 taxable year.                                                              




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