- 34 - respectively, which respondent denied for lack of substantiation. The Bensons conceded respondent’s determination for all years except 1994. See appendix, par. 13. 6. Evelyn Hermsmeier Partnership During the years 1988, 1989, 1990, and 1993, Elizabeth was a partner holding a 50-percent interest in the Evelyn C. Hermsmeier et al. partnership. Evelyn C. Hermsmeier, f.k.a. E.C. Ford, is the sister of Elizabeth. For the years listed, gross income of the partnership was as follows:40 Tax Year Gross Income 1988 $263,448 1989 274,683 1990 242,700 1991 282,059 1992 202,192 1993 185,770 1994 201,239 7. The Income Tax Returns (a) The Bensons On July 25, 1994, the Bensons filed their 1988 Federal income tax return through respondent’s revenue agent. The 1988 return was filed after the October 15, 1989, due date, as extended. On September 16, 1994, the Bensons filed their 1989 Federal income tax return through respondent’s revenue agent. 40On brief, respondent indicated that facts pertaining to the Evelyn Hermsmeier Partnership relate “solely to the issue of substantial omission of income pursuant to” sec. 6501(e). Income or loss from the partnership was reported on the Bensons’ 1989, 1990, 1993, and 1994 Schs. E as Elizabeth’s distributive share.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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