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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.
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