Gregory H. and Elizabeth A. Price - Page 17





                                       - 17 -                                         

          Partnership Adjustments - Contested by                                      
          Petitioners (Stores 4, 5, and 7):                1989         1990         1991
               Unexplained bank deposits          $146,609  $266,352                  
               Depreciation recapture on Store 5  $170,267                            
               Depreciation of videos             12,951      (35,958)     (41,429)   
               Total adjustments to partnership income$159,560     $230,394     $128,838  
               Petitioner's one-half interest in total                                
               partnership adjustments            $ 79,780     $115,197   $ 64,419    
          Individual Adjustments:                                                     
          Contested by Petitioners:                                                   
               Unexplained bank deposits            $117,514                          
               Rental income                          1,891                           
               Depreciation of videos                           359  $ 48,209        
               Repair and maintenance expenses    $    893  3,486      1,020          
          Conceded by Petitioners or                                                  
          Mechanical Adjustments:                                                     
               State tax refund                             240          443          
               Rental interest paid               2,453                               
               Rental depreciation                3,540     3,540      3,540          
               Capital gains/losses                                  (298)           
               Self-employment tax deduction                (3,924)     (1,076)       
               Itemized deductions                (3,964)   (4,454)      1,662        
               Exemption adjustment                                         387       
               Corrected individual adjustments                                       
               before partnership adjustments     $  2,922     $118,652     $ 53,887  
          Total combined individual adjustments to                                    
          taxable income and to petitioner's one-half                                 
          interest in total partnership income                                        
          adjustments                             $ 82,702     $233,849     $118,306  

          Fraud (1989 and 1990) Penalties, Accuracy-                                  
          Related Penalty, and Additions to Tax                                       

               For 1989, 1990, and 1991, petitioners untimely filed their             

          joint Federal income tax returns.                                           

               Petitioners reported on their 1989, 1990, and 1991 joint               

          Federal income tax returns the following taxable income:                    


                                        Year                                          
                                        1989      1990      1991                      
               Reported taxable income   -0-      -0-       $22,967                   









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