- 7 -
on the Harlan’s 1985 Form 1040 and on the first-tier partnership
returns of the partnerships in which Ridge or Marjory Harlan
owned a direct interest”, i.e., excluding “the flow of gross
income from” the 2d-tier partnerships, is $1,410,077.
B. The Ockels
The Ockels filed their 1985 joint tax return on October 15,
1986. On August 11, 1992, respondent issued a notice of
deficiency to the Ockels for 1985.
The 3-year period of limitations for assessment of tax under
section 6501(a) with respect to the Ockels for 1985 expired
before the notice of deficiency was mailed. The Ockels did not
execute any extensions of the period of limitations on assessment
with respect to 1985.
The Ockels’ 1985 tax return has, attached to the Form 1040,
the following: Schedules A, B, C, D, E, and SE; Forms 2688,
3468, 4797, 6198, 6251, 4684, 8283, 4255, 4562, 4868, 4952, 8082,
6248; and numerous schedules, attachments, and other documents.
The Ockels’ 1985 tax return shows net income of $7,900 from
several partnerships and one independent oil producer, identified
by name and employer identification number. The record includes
1985 partnership information returns, or parts of those returns,
from each of the identified partnerships, and a 1985 windfall
profit tax information return (Form 6248) from the oil producer,
as well as stipulations as to Theodore’s shares of the
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