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In addition to transactions not reported on Schedule D of
petitioners' 1987 return, petitioners failed to report: Rental
income of $1,608 received from Solon Automated Services; an IRA
distribution of $1,830 received from Putnam Option Income Trust;
and interest income totaling $1,711 from various partnerships and
banks. Finally, during 1987, Ms. Bach contributed $4,000 to her
IRA held by Putnam Option Income Trust.
Petitioners filed their 1987 Federal income tax return with
the Internal Revenue Service Center at Philadelphia,
Pennsylvania, on November 21, 1988.
OPINION
Recognition of Gain or Loss on Disposition of Partnership
Interests
Respondent determined a deficiency for 1987 due to capital
gains not reported by petitioners on the disposition of several
partnership interests as follows:
Partnership Capital Gain
America/Bradley $448,756
JAMA 213,535
Bay Country 189,802
Diamond Farms 66,823
Wazee Street 39,432
Glenwood 4,208
Russell Street 21,005
Total $983,561
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