- 5 - In 1982 and 1983, petitioners paid a total of only $39,170 and $50,000, respectively, in estimated and withheld Federal income taxes. On petitioners’ jointly filed Federal income tax returns for 1982 and 1983, petitioners reported $649,177 and $1,027,000 in income from petitioner’s medical practice, and petitioners claimed net losses of $575,171 and $671,937, respectively, relating to petitioners’ various tax-sheltered partnership investments, including losses relating to Blythe II of $83,732 and $4,024, respectively, for those years. On audit, respondent disallowed the claimed losses relating to petitioners’ investment in Blythe II. William G. Kellen, the tax matters partner of Blythe II, initiated a proceeding under the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324, 648, and signed a stipulation to be bound by the decision entered in Utah Jojoba I Research v. Commissioner, T.C. Memo. 1998-6 (Utah I). As a result of the final resolution of Utah I (wherein claimed section 174 research and experimental expenses and losses similar to those claimed by Blythe II were disallowed), the tax deficiencies relating to petitioners’ investment in Blythe II are conceded by petitioners.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011