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On October 16, 1997, Trisch filed amended Forms 1065 and
Schedules K-1, Partner’s Share of Income, Credits, Deductions,
etc., for DRD for 1992 and 1993 showing that all DRD income,
deductions, losses, and credits were attributable to him.
2. Petitioners’ Individual Income Tax Returns
Petitioners timely filed joint Federal income tax returns
for 1989 through 1993. Petitioners received Schedules K-1 for
DRD that showed the following:
Net
Capital Capital Ordinary income(loss)
account account income rental
beginning end trade or real estate
Year of year of year business activities
1989 $139,590 $159,264 $55,964 ($38,754)
1990 159,263 188,127 21,099 (15,472)
19901 159,263 187,777 70,746 (32,432)
1991 187,777 154,783 (5,105) (23,394)
1992 154,783 341,030 223,893 (44,493)
19922 154,783 -0- -0- –-
19933 279,171 351,003 88,796 (36,876)
19934 -0- -0- -0- -0-
1 The amounts for the second entry for 1990 are those reported
on DRD’s amended return for 1990.
2 The amounts for the second entry for 1992 are those reported
on DRD’s amended return for 1992 filed in October 1997.
3 There is no explanation in the record for why the capital
account beginning in 1993 is not the same as the ending capital
account for 1992.
4 The amounts for the second entry for 1993 are those reported
on DRD’s amended return for 1993 filed in October 1997.
Petitioners received the Schedules K-1 each year after they
had prepared their individual returns for the year, except for
1989. Petitioners believed that their income tax returns had to
be consistent with the Schedules K-1, so they filed amended
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