- 34 - Falls Investors, L.P.,16 for 1996, 1997, and 1998. RA Colline did not receive any information regarding Hofflund Polone from petitioner, and Mr. Harbin provided information only for 1998 regarding Bedford Falls Investors, L.P. In the November 8 IDR, RA Colline also requested copies of petitioner’s 1997 and 1998 income tax returns. Mr. Harbin eventually sent petitioner’s 1998 return after RA Colline advised him that she had obtained copies of petitioner’s 1997 return. During the examination, RA Colline requested an interview with petitioner to gather information about, and petitioner’s explanation of, items on petitioner’s returns that were under examination. Mr. Harbin absolutely refused to allow petitioner to be interviewed. Petitioner testified for over 4-1/2 hours during the trial of this case. Respondent’s Determination and Denial of Petitioner’s Refund Claim On or about February 15, 2000, respondent denied petitioner’s claim for refund for 1996 (relating to the November 1996 payment). The reason for disallowance was that the $1 million payment associated with petitioner’s refund request did not qualify as tax-free income. In the notice of deficiency, respondent determined that the May 1996 payment, the May 1997 payment, and the November 1998 16 Bedford Falls Investors, L.P., was listed as a partnership petitioner received income or loss from on Schedule D of his 1996, 1997, and 1998 returns.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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