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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
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Last modified: May 25, 2011