- 13 - 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 ofPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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