Mark J. Steel and Connie J. Steel - Page 6




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                                   Amount              Ownership                      
                    Partner           Received         Percentage                     
               Mr. Huse            $68,870             39.68%                         
               Mr. Nymark          68,870              39.68                          
               Mr. Steel              34,435           20.64                          
               Total               172,175                                            
          In July 1997, the Bochica partners and the insurer settled the              
          lawsuit for $1.5 million, which was also distributed to the                 
          general partners according to their respective interests:                   
                                   Amount              Ownership                      
                    Partner           Received         Percentage                     
               Mr. Huse            $595,238            39.68%                         
               Mr. Nymark          595,238             39.68                          
               Mr. Steel           309,524             20.64                          
                Total         1,500,000                                               
               After accounting for expenses of the lawsuit, Mr. and Mrs.             
          Huse and Mr. and Mrs. Steel reported the amounts received in 1996           
          and 1997 as long-term capital gain on Schedules D, Capital Gains            
          and Losses, of their Forms 1040, U.S. Individual Income Tax                 
          Return, in the following amounts:                                           
                                   1996             1997                              
               Mr. Huse            $60,342        ---                                 
               Mr. & Mrs. Huse     ---            $557,359                            
               Mr. & Mrs. Steel    30,001         289,827                             
          On March 30, 2000, respondent issued notices of deficiency to Mr.           
          and Mrs. Steel for 1996 and 1997, to Mr. Huse for 1996, and to              
          Mr. and Mrs. Huse for 1997, in which he determined:                         
               We have reduced the amount of the capital gain that you                
               reported by the amounts you received and identified as                 
               additional stock proceeds.  It has been determined that                




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