- 2 -
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $1,504 $376 --
1992 90,846 22,567 $3,937
1993 28,820 7,213 1,209
The parties have settled all issues except whether
petitioner incurred a loss in any year in issue from Arcanum One
Partners (Arcanum), a New York limited partnership, and, if so,
the amount of the loss.
By stipulation of settled issues, the parties agreed to the
amount of petitioner’s deficiencies in tax for 1991, 1992, and
1993, and additions to tax for those years. The parties also
stipulated that any loss that petitioner may have incurred from
Arcanum will offset the stipulated deficiencies. After
concessions, the issues for decision are:
1. Whether petitioner is bound by the stipulation of
settled issues. We hold that he is.
2. Whether we have jurisdiction to decide whether
petitioner incurred a loss from Arcanum. We have jurisdiction if
Arcanum is a small partnership under section 6231(a)(1)(B) and
thus excepted from the unified partnership procedures. We hold
that we lack jurisdiction because Arcanum is not a small
partnership.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011