Michael Buchsbaum - Page 5




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          determine any deficiencies based on adjustments to partnership              
          items.  Petitioner filed a petition in which he contended, among            
          other things, that he had incurred a loss from Arcanum, which               
          would offset the deficiencies determined.                                   
               The parties filed a stipulation of settled issues about                
          1 year before trial.  In it, the parties stipulated that                    
          petitioner is liable for the following:                                     
                    1.  Subject to the provisions of paragraph 4,                     
               below, there are deficiencies in income tax due from                   
               petitioner in the amounts of $31,804.00, [$]71,964.00,                 
               and [$]9,747 for the taxable years 1991, 1992, and                     
               1993, respectively.  It is further stipulated that                     
               respondent claims an increased deficiency in income tax                
               for the taxable year 1991 in the amount of $30,300.00,                 
               pursuant to the provisions of I.R.C. � 6214(a).                        
                    2.  Subject to the provisions of paragraph 4,                     
               below, petitioner is liable for delinquency penalties                  
               under I.R.C. � 6651(a)(1) in the amounts of $7,771.00,                 
               $17,991.00, and $2,436.75 for taxable years 1991, 1992,                
               and 1993, respectively.  It is further stipulated that                 
               respondent claims an increased delinquency penalty for                 
               the taxable year 1991 in the amount of $7,395.00,                      
               pursuant to the provisions of I.R.C. � 6214(a).                        
                    3.  Subject to the provisions of paragraph 4,                     
               below, petitioner is liable for estimated tax penalties                
               under I.R.C. � 6654 in the amounts of $1,776.47,                       
               $3,138.77, and $408.38 for taxable years 1991, 1992,                   
               and 1993, respectively.  It is further stipulated that                 
               respondent claims an increased estimated tax penalty                   
               for the taxable year 1991 in the amount of $1,776.47,                  
               pursuant to the provisions of I.R.C. � 6214(a).                        
                    4.  This stipulation resolves all issues in the                   
               case with the exception of the issues raised by                        
               petitioner in his petition, to wit, whether petitioner                 
               has incurred a loss from Arcanum One Partners, a New                   
               York limited partnership, in any year at issue, which                  







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