Michael C. Hollen and Joan L. Hollen - Page 2




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          $3,965 and $19,827, respectively.1  After concessions,2 the                 
          issues for decision are:  (1) Whether petitioners were required             
          to report and pay income tax on a one-third distributive share of           
          partnership income from Blue Bird Ranch Partnership (the                    
          partnership) in 1988, and (2) whether petitioners are liable for            
          the additions to tax determined by respondent.  We resolve both             
          issues in favor of respondent.                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulated                
          facts are incorporated in our findings by this reference.                   
               On the date the petition in this case was filed, petitioners           
          were married and resided in Waterloo, Iowa.  Michael C. Hollen              
          (petitioner) is a dentist who, during all relevant periods,                 
          operated a professional dental practice through his professional            




               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               2In the notice of deficiency, respondent determined that               
          petitioners had unreported taxable gain of $280,275, representing           
          50 percent of the partnership’s gain from the sale of the ranch             
          property.  Respondent now concedes that only one-third of the               
          gain from the sale of the property in 1988; i.e., $195,425, is              
          allocable to petitioners.  Petitioners concede that they received           
          taxable income of $150 from Hawkeye Institute of Technology, $833           
          from petitioner’s professional corporation, and $89 of interest             
          from the Blue Bird Ranch Partnership that was not reported on               
          their Federal income tax return for 1988.                                   





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