Jerry and Patricia A. Dixon, et al - Page 186




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               On February 28, 1980, the Alexanders filed a timely petition           
          with the Court, assigned docket No. 2758-80, contesting the                 
          notice of deficiency for 1974 and 1975.                                     
               2.   1976 and 1977                                                     
               Respondent also examined the Alexanders' joint income tax              
          returns for 1976 and 1977.  On April 17, 1986, respondent issued            
          the Alexanders a notice of deficiency determining deficiencies in           
          and additions to their 1976 and 1977 Federal income taxes, as               
          follows:                                                                    
          Additions to Tax                                                            
          Year         Deficiency          Sec. 6653(a)                               
          1976           $3,596                 $180                                  
          1977              876                   44                                  
          Respondent also determined that the Alexanders were liable for              
          increased interest for 1976 pursuant to section 6621(c).                    
          The deficiencies that respondent determined against the                     
          Alexanders for 1976 and 1977 resulted, in part, from respondent's           
          disallowance of interest deductions of $8,665 and $12,993,                  
          respectively, attributable to their participation in Kersting               
          programs for those years.  Respondent also disallowed a $5,149              
          partnership loss claimed by the Alexanders for 1976 on their                
          investment in the Avista Epsilon and Sarbonne partnership.                  
               On July 21, 1986, the Alexanders filed a petition through              
          Mr. Kersting's office, assigned docket No. 30413-86, contesting             
          the notice of deficiency for 1976 and 1977.                                 





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