- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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