Victor M. Bello - Page 11




                                       - 11 -                                         
          partnership unit.  From 1992 through 1994, petitioner was a                 
          partner in Roadmaster Leasing.                                              
               As a result of advice petitioner received from another                 
          accountant (who was hired to help with the financial management             
          of his medical business and other investments), he made no                  
          further capital contributions to Roadmaster Leasing after 1993.             
          This accountant had advised him to end his involvement with                 
          Roadmaster Leasing.                                                         
               On his 1992 return, petitioner claimed an ordinary                     
          partnership loss of $5,000 from Roadmaster Leasing.  On his 1994            
          return, he claimed an ordinary partnership loss of $3,558 from              
          Roadmaster Leasing.  Petitioner attached no information returns             
          for partners with respect to Roadmaster Leasing to his 1992,                
          1993, and 1994 returns.                                                     
               The Internal Revenue Service has no record of any business             
          activity, financial operation, or venture that was actually                 
          carried on by Roadmaster Leasing from 1992 through 1994.                    
          Roadmaster Leasing never filed a partnership return for those               
          years.                                                                      
          Notice of Deficiency                                                        
               In the notice of deficiency issued to petitioner for 1992,             
          1993, 1994, and 1995, respondent disallowed various deductions              
          petitioner had claimed from Villa del Mar, Amazona, and                     
          Roadmaster Leasing.  The notice of deficiency stated, in                    






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

Last modified: May 25, 2011