- 24 - Mr. Gaskins 1990 1991 Share of partnership income $439,316 $742,593 Self-employment tax deduction (1,635) (4,971) Deduction for exemptions 8,600 Total adjustments 437,681 746,222 Reported income 27,753 42,626 Adjusted income 465,434 788,848 OPINION Unreported Sales The first issue for decision is whether unreported income in the amount of $888,528 in 1990 and $1,054,576 in 1991 should be included in Beaufort Leaf's gross receipts, as determined by respondent. If Beaufort Leaf's gross receipts are increased as determined by respondent, then a one-third distributive share of the additional partnership income attributable to this adjustment is includable in the income of each petitioner. See sec. 702(a); United States v. Basye, 410 U.S. 441, 453-454 (1973). Petitioners advance two arguments in support of their position that respondent erred by increasing Beaufort Leaf's gross receipts. First, they argue that the sales that are the source of the unreported income were outside the scope of the business of Beaufort Leaf. Accordingly, petitioners argue that the unreported income is the income of Mr. Roberts, not the income of Beaufort Leaf, and therePage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011