Donald B. Hawksley - Page 13




                                       - 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 of               





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

Last modified: May 25, 2011