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Tax Year Deficiency
1990 $35,219
1991 60,129
1992 66,435
After concessions, the only issue is whether payments received by
petitioners in 1990, 1991, and 1992 should have been reported as
income in those years.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Some of the facts have been stipulated and are so found.
The stipulation of facts, with accompanying exhibits, is
incorporated by this reference. We need find few facts in
addition to those stipulated and, accordingly, will not
separately set forth those findings. We include our additional
findings of fact in the discussion that follows. Petitioners
bear the burden of proof on all questions of fact. Rule 142(a).
Background
At the time the petition was filed, petitioners resided in
Park Rapids, Minnesota. Petitioners filed joint returns for the
taxable (calendar) years in question and used the cash method of
accounting.
From about November 1, 1980, until sometime in the late
1980's, petitioner Larry A. Monico (Larry Monico) was an equal
partner with R.D. Offut Co. (Offut Co.), a Minnesota corporation,
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Last modified: May 25, 2011