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tax deficiency for 1986. The $23,785.64 abatement for 1986
represented the income tax attributable to respondent’s allowance
of the previously disallowed Schedule E Barrington Park
partnership loss of $26,710 and the gift tax basis in the shares
of United Funds, Inc. of $21,365.
E. Additional Abatements Related to a Problem Solving Day in
1998
On April 22, 1998, petitioner attended one of respondent’s
Problem Solving Days and provided documentation substantiating
$20,222, or 85 percent, of the total deductions ($23,791) claimed
by petitioner on his Schedule C for 1986. Respondent then
extrapolated from this substantiation and allowed petitioner
$30,723, or 85 percent, of the total deductions ($36,145) claimed
by petitioner on his Schedule C for 1985.
On May 11, 1998, and as a consequence of the foregoing
allowance, respondent abated $8,525 of the original income tax
deficiency assessment of $9,423 for 1985 and fully abated the
assessed additions to tax under sections 6653(a)(1) and (2) and
6661 for that year. The $8,525 abatement represented the tax
attributable to the allowance of $30,723 in Schedule C deductions
for 1985. This abatement resulted in a net assessed deficiency
in income tax of $898 for 1985.
Also on May 11, 1998, and again as a consequence of the
allowance made on the Problem Solving Day, respondent abated
$9,453.66 of the original income tax deficiency assessment of
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