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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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