Jerry and Patricia A. Dixon, et al - Page 175




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               1.   1974 and 1975                                                     
               Mr. Alexander and his wife, Freida, filed joint Federal                
          income tax returns for the taxable years 1974, 1975, 1976, and              
          1977.  Following an examination of their returns for 1974 and               
          1975, the Alexanders conceded certain adjustments proposed by               
          respondent, resulting in agreed assessments of $2,133 and $811              
          for 1974 and 1975, respectively.15  However, because the                    
          Alexanders declined to agree to other proposed adjustments,                 
          respondent, on November 29, 1979, issued a notice of deficiency             
          determining deficiencies of $4,891.83 and $40,760.38,                       
          respectively, in their Federal income taxes for 1974 and 1975.              
               Respondent's deficiency determinations against the                     
          Alexanders for 1974 and 1975 were based, in part, on disallowance           
          of interest deductions of $2,917 and $46,500, respectively,                 
          attributable to their participation in Kersting programs for                
          those taxable years.  Additional adjustments included                       
          disallowance of an $18,500 capital loss claimed by the Alexanders           
          for 1974 on a sale of stock in Mendocino Financial Corp. and                
          respondent's determination that they had failed to report a                 
          $59,080 capital gain for 1975 from a sale of real estate to the             
          Cadillac Drive Apartments partnership.                                      



          15  The Alexanders were represented during the audit                        
          by their accountant, Gilbert Matsumoto (Mr. Matsumoto).  Mr.                
          Matsumoto had served as the accountant for some of Mr. Kersting's           
          subchapter S leasing corporations, and Mr. Kersting had                     
          recommended that program participants use Mr. Matsumoto, among              
          others, to prepare their tax returns.                                       

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