- 15 -
and all of the plan's assets were distributed into the IRA
rollover account.
The Partnership's Return Position
On its Form 1065, U.S. Partnership Return of Income,
for 1986, the partnership deducted total contributions to
defined benefit plans on behalf of its partners in the
amount of $1,212,474.90. Of that amount, $20,611 had
allegedly been contributed to Mr. Stein's defined benefit
plan, a contribution of $4,111 made to the plan on June 24,
1986, and the alleged contribution of 2,000 shares of
Saztec stock, valued at $16,500, described above.
Respondent issued a timely notice of FPAA to the tax
matters partner. In the notice, respondent adjusted the
deduction claimed by the partnership for contributions to
defined benefit pension plans, from $1,212,475 to
$1,195,975. Thus, respondent disallowed the partnership's
deduction of $16,500, the value of the shares of Saztec
stock which the partnership claimed to have contributed to
the plan. The notice describes this adjustment as follows:
The contribution of $16,500 deemed to have been
made to the Reed Smith Shaw & McClay/Arland T.
Stein Defined Benefit Pension Plan (No. 125) is
disallowed because you have failed to establish
that the contribution [of] 2,000 shares of
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011