Linda Klyce - Page 8




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          (1) the correct amount of gross income for 1992 and 1993, and (2)           
          interest expense deductions for 1992 and 1993.  Finally, the                
          parties stipulated each item of income and expense in connection            
          with Special O for 1991, 1992, and 1993, with the exception of              
          (1) travel expense deductions for 1991, 1992, and 1993; (2)                 
          interest expense deductions for 1991, 1992, and 1993; (3) the               
          correct amount of gross income for 1992 and 1993; and (4) a                 
          section 179 expense deduction for 1993.  At trial, petitioner               
          conceded the interest expense deductions for 1991, 1992, and                
          1993, with respect to Special O and the interest expense                    
          deductions of Special Occasions for 1992 and 1993.3                         
               Section 61 defines gross income as all income from whatever            
          source derived.  With respect to a partnership, each partner                
          shall take into account separately his or her distributive share            
          of the partnership's taxable income or loss.  See secs.                     


          3                                                                           
               Notices of deficiency were issued by respondent to each of             
          petitioner's sisters, making adjustments to income and deductions           
          that flowed through to them from the entities in which they were            
          involved with petitioner.  Each of the sisters filed a petition             
          with this Court.  Their cases, the years involved, and the                  
          opinions of the Court are referenced as follows:                            
               Johnny and Faye W. Oatis, docket No. 17068-96S, 1992 and               
               1993, T.C. Summary Opinion 1998-88                                     
               Barbara J. Wilson, docket No. 17067-96S, 1992 and 1993, T.C.           
               Summary Opinion 1998-99                                                
               Marian Wilson, docket No. 12687-97, 1991, 1992, and 1993,              
               T.C. Memo. 1999-141                                                    




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