Donnie F. Schroeder - Page 5




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          1996 taxable year.  A Schedule K-1 was attached to Quality’s 1996           
          return.  The Schedule K-1 listed petitioner as a general partner            
          of Quality with a 50-percent interest in profit sharing, loss               
          sharing, and ownership of capital.  The Schedule K-1 listed                 
          petitioner’s distributive share of Quality’s ordinary income,               
          interest income, and section 1231 gain for the 1996 taxable year            
          as $40,697, $1,411, and $311, respectively.  The Schedule K-1               
          also listed petitioner’s distributive share of Quality’s section            
          179 expense deduction and other deductions as $644 and $800,                
          respectively.                                                               
               During the course of trial preparation, respondent                     
          discovered that petitioner had additional income from Quality.              
          In the amendment to answer, respondent asserted that petitioner             
          had the following additional amounts of unreported gross income             
          in 1996 with respect to his partnership interest in Quality:  (1)           
          Ordinary income in the amount of $40,697; (2) section 1231 gain             
          in the amount of $311; and (3) interest income in the amount of             
          $1,411.  With respect to petitioner’s partnership interest in               
          Quality, respondent allowed petitioner a section 179 expense                
          deduction and other deductions in the amounts of $644 and $800,             
          respectively.  Respondent also increased petitioner’s self-                 
          employment tax and allowed a corresponding deduction.  Petitioner           
          has not specifically contested the applicability of the                     
          employment tax and related deductions, and we deem that he has              






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