Don L. and Lora Christensen - Page 4




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          $3,638.04.  Petitioners reported total net losses from numerous             
          partnerships, one rental property, and one small business                   
          corporation of $405,006.93 for 1982, of which $41,866 was the               
          loss from Blythe II.  Thus, petitioners reported total income of            
          $209,272.73 and a total tax liability of $39,115.20.3                       
               On their joint 1983 Federal income tax return, petitioners             
          reported wages of $611,826.06 from petitioner's medical practice,           
          interest income of $52,660.89, capital gains of $96,412.52, and             
          other income of $1,251.16.  Petitioners reported total net losses           
          from numerous partnerships and two rental properties of                     
          $380,465.98 for 1983, of which $2,012 represented the loss from             
          Blythe II.  Thus, petitioners reported total income of                      
          $381,684.65 and a total tax liability of $128,567.4                         


               3    During April 1986, petitioners filed an amended return            
          for 1982 reporting a decrease in total income of $5,500 due to an           
          additional $5,500 loss in connection with Arrowhead Village, a              
          real estate partnership promoted by Mr. Sheets.  On the amended             
          return, petitioners reported a total tax liability of $36,365.20.           
               4    During March 1985, petitioners filed an amended return            
          for 1983 reporting a decrease in total income of $15,073 due to             
          Mr. Hulse's mistaken reporting on their original return of                  
          $15,073 in partnership income that was not attributable to                  
          petitioners.  On the amended return, petitioners reported a total           
          tax liability of $121,212.  During July 1985, petitioners filed a           
          second amended return for 1983, reporting an increase in                    
          deductions of $17,229.34 for various interest paid, charitable              
          contributions, and business expenses.  On the second amended                
          return, petitioners reported a total tax liability of $112,416.             
          During April 1997, petitioners filed a third amended return for             
          1983 reporting a decrease in total income of $4,268.69 due to an            
          additional $4,268.69 loss in connection with the aforementioned             
                                                             (continued...)           





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