Marian Wilson - Page 6




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          from Special Occasions on Schedules E in the amounts of $2,950,5            
          $5,600, and $2,6896 for the 1991, 1992, and 1993 tax years,                 
          respectively.  Special Occasions did not file a U.S. Partnership            
          Return of Income, Form 1065, for the 1991 tax year.                         
               In a notice of deficiency dated March 14, 1997, respondent             
          disallowed petitioner's claimed Schedule E losses for the 1991,             
          1992, and 1993 tax years because petitioner did not provide any             
          documentation to establish her bases in Special Occasions and               
          Special O for the years in issue.                                           
                                       OPINION                                        
          1.  Petitioner's Basis in Special Occasions                                 
               As a preliminary matter, this Court notes that the business            
          accounting books and records purportedly maintained by Special              
          Occasions and Special O, such as they are, are not reliable.                
          Furthermore, petitioner's own books and records were poorly                 
          maintained and are incomplete.  In response to the disorganized             
          and sparse records offered by petitioner in this case, respondent           
          has submitted alternative bases calculations for petitioner's               
          business interests in both Special Occasions and Special O.                 


          5    Though reported, petitioner concedes that she is not                   
          entitled to claim a nonpassive loss from Special Occasions in the           
          amount of $2,950 for the 1991 tax year.                                     
          6    Though petitioner reported 1993 losses from Special                    
          Occasions in the amount of $2,689 on her Federal income tax                 
          return, the parties stipulated 1993 losses from Special Occasions           
          in the amount of $2,699.                                                    




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