Peter M. and Susan L. Hoffman - Page 14

          (1967).  Accordingly, to satisfy the burden of going forward,               
          respondent must provide evidence to show the amounts of gross               
          income reported on the partnership and S corporation returns or             
          to show that no such returns were filed.  Davenport v.                      
          Commissioner, supra at 928; Roschuni v. Commissioner, 44 T.C. 80            
               Respondent has provided none of the income tax returns for             
          the six partnerships of which petitioners were partners.                    
          Moreover, respondent has not alleged, much less established, that           
          any of the six partnerships failed to file returns for 1990.                
          Instead, respondent alleges that his burden of going forward does           
          not include production of the partnership returns.  We disagree.            
               The 6-year period of limitations provided for in section               
          6501(e) is implicated if the taxpayer omitted from gross income             
          an amount greater than 25 percent of the taxpayer’s gross income            
          as stated on the Federal income tax return.  The amount                     
          petitioners omitted, the numerator in the calculation, is not in            
          dispute in this case.  The amount omitted is $779,114.  The                 
          parties disagree, however, as to the amount of gross income                 
          stated in their return.                                                     
               Gross income is not defined in section 6501.  We have held,            
          however, that the general definition of gross income found in the           
          Code applies to section 6501(e), except for the modification                
          provided in section 6501(e)(1)(A)(i).  N. Ind. Pub. Serv. Co. &             

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