- 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, inPage: 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