- 5 - 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 hasPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011