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business activities, of the Partnership's Forms 1065, U.S.
Partnership Return of Income, for 1987 through 1990 as follows:
Year Adjustment
1987 $1,070,445
1988 677,229
1989 (311,234)
1990 (290,088)
Under the Decision, petitioners' share of Partnership losses was
increased to 48 percent of the adjusted Partnership losses for
1989 and 1990, or $646,529 and $739,430, respectively.
Petitioners subsequently filed Forms 1040X, Amended U.S.
Individual Income Tax Return, for taxable years 1989 and 1990.
Applying the adjustments contained in the Decision to their
original returns, petitioners claimed overpayments in the amounts
of $71,602 and $12,889, and net operating losses of $68,270 and
$278,658, for 1989 and 1990, respectively. Petitioners also
filed amended returns for 1987 and 1988, claiming overpayments in
the amounts of $93,467 and $19,689, respectively, as a result of
net operating loss carrybacks from 1989 and 1990.
On February 19, 1997, respondent made computational
adjustments on Forms 4549-A, Income Tax Examination Changes, to
petitioners' taxable years 1987 through 1990. For 1987 and 1988,
the computational adjustments reflect the adjustments to
partnership items set forth in the Decision for those years, and
determine deficiencies in the amounts of $65,053 and $14,538,
respectively. For 1989 and 1990, respondent determined
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