- 6 - Respondent issued a notice of deficiency on April 1, 1999. The notice5 (1) disallowed some of the deductions claimed on Schedule C; (2) determined that petitioner failed to report dividend and interest income of $95 in 1990, $5,493 in 1991, and $253 in 1993; and (3) made adjustments to petitioners’ itemized deductions on Schedule A. As to the itemized deductions on Schedule A, the notice of deficiency indicated the following: It is determined that interest expense deduction of $76,098.00, $84,638.00 and $67,297.00 respectively for the taxable years ended December 31, 1990, 1991 and 1993 is allowable instead of $86,128.00, $100,865.00 and $58,292.00 respectively as shown on your tax returns for the taxable years ended December 31, 1990, 1991 and 1993. Accordingly, your taxable income is increased $10,030.00 and $16,227.00 for the taxable years ended December 31, 1990 and 1991, and your taxable income is decreased $9,005.00 for the taxable year ended December 31, 1993.[6] [Emphasis added.] Respondent also determined that petitioner was liable for the accuracy-related penalty pursuant to section 6662(a). Respondent served petitioners with interrogatories and a request for production of documents on January 27, 2000. Petitioners failed to respond to the formal discovery, and respondent filed motions to compel responses to interrogatories 5 Although the explanation in the notice of deficiency appears to disallow the claimed investment credit, the notice does not contain an adjustment to this item. 6 The decrease in income for 1993 is due to a carryforward of disallowed interest under sec. 163(d) from 1991. The carryforward amount will be affected by our holding with respect to 1991 and can be accounted for in the Rule 155 computation.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