- 2 - $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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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