- 2 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011