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All of the payments were reflected in Forms K-1, Partner’s Share
of Income, Credits, Deductions, etc., as petitioner’s share of
the firm’s annual partnership income.
Petitioner reported the receipt of the $48,420 on his 1993
Federal income tax return using Form 8082, Notice of Inconsistent
Treatment or Amended Return. On the Form 8082, petitioner
reported a difference of $48,420 from the amount reflected on his
Form K-1 for Winston’s tax year ending January 31, 1993, and the
amount reported as income on his 1993 Federal tax return.
Petitioner included, as an attachment to the Form 8082, a
detailed explanation of the difference. The explanation
reflected that petitioner was in the process of being severed as
a partner from Winston and that the amount and character of his
severance agreement were still in dispute. The explanation
further reflected that the $48,420 in payments was not taxable
income until the severance agreement and character of the
payments were resolved.
Petitioner, using a Form 8082, reported the $48,420 as
income on his 1995 Federal income tax return. He reflected a
$48,2405 difference from the amount shown as income on his Form
K-1 from Winston, for its tax year ending January 31, 1995.
Petitioner provided the explanation that the difference was due
5 Petitioner reported a $48,240 difference on Form 8082,
Notice of Inconsistent Treatment or Amended Return; however, the
amount of advances received by petitioner totaled $48,420.
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