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shares of partnership items reported on the partnership return
for 1985.
On July 2, 1990, respondent issued an FPAA to petitioner and
SGE’s TMP relating to the partnership return filed for the 1986
tax year. In the Explanation of Adjustments included with the
FPAA, respondent made adjustments to SGE’s partnership return
reducing all items reported during the 1986 tax year to zero.
The following items reported on SGE’s 1986 partnership return
were reduced to zero: (1) Farm income totaling $123,434; (2)
farm deductions totaling $1,948,760; (3) guaranteed payments
totaling $31,234; (4) IRA payments totaling $52,000; (5) Keogh
payments totaling $8,000; and (6) self-employment loss totaling
$1,825,326. Again, the explanation listed the various reasons
why SGE was not entitled to the items reported and why the
partners were not entitled to their distributive shares of those
items.
E. Litigation Relating to SGE for Tax Years 1985 and 1986
On September 8, 1989, a petition was filed in the Tax Court
at docket No. 22069-89, contesting the determinations made by
respondent in the FPAA for SGE’s 1985 tax year. On October 1,
1990, a petition was filed with this Court at docket No. 21954-
90, contesting the determinations made in the FPAA for SGE’s 1986
tax year.
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