- 6 - Respondent’s Adjustments Respondent’s adjustments giving rise to the deficiencies here in question (sometimes, the deficiencies) result from respondent’s disallowances of the Vulcan losses and a small credit (without distinction, the Vulcan losses) claimed on the joint returns. In the notice, respondent explains the disallowances as follows: It is determined that you incurred no deductible loss for the taxable years 1981 and 1982 from the Vulcan Oil Technology a partnership in which you own an interest. It has not been established that the partnership incurred any loss for the taxable years 1981 and 1982, nor has it been established that if the partnership did have a loss for the taxable years 1981 and 1982, that you are entitled to deduct any portion of that loss on your income tax return. Accordingly, your taxable income for the years 1981 and 1982 is increased by $75,620.00 and $71,078.00. After the initiation of this action, and following respondent’s prevailing in certain test cases involving investments similar to Vulcan (the test cases),5 petitioners conceded the deficiencies. The Jonsons Barbara was born on March 21, 1930. She received an associate’s degree from Colorado Women’s College in 1949, a 5 On brief, petitioners identify those cases as follows: Krause v. Commissioner, 99 T.C. 132 (1992), affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024 (10th Cir. 1994); and Acierno v. Commissioner, T.C. Memo. 1997-441, affd. 185 F.3d 861 (3d Cir. 1999).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