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opportunity for administrative review in the IRS Office of
Appeals, for 1984 was mailed on March 6, 1991.
On June 19, 1992, and October 8, 1992, respondent sent
notices of deficiency to petitioner and Trupin for 1982 through
1986. For 1982 through 1986, respondent determined deficiencies
of $503,139, $443,704, $1,265,273, $2,939,540, and $215,003,
respectively, and additions to tax pursuant to section 6661 of
$125,785, $110,926, $316,318, $734,885, and $53,751,
respectively. In the notices of deficiency for 1982 through
1986, respondent determined that petitioner and Trupin received
additional income from their unreimbursed personal use of the
corporate yacht of $706,077, $603,012, $941,859, $663,312, and
$765,000, respectively.
In the notice of deficiency for 1982 and 1983, respondent
disallowed the partnership losses from petitioner’s investment in
ANA 367 of $152,073 and $223,155, respectively, and investment
interest expenses in 1983 for ANA 367 of $107,260.
On August 3, 1992, a petition was filed in this Court at
docket No. 17389-92 on behalf of Trupin and petitioner contesting
their Federal income tax liabilities for 1982 and 1983. On
December 3, 1992, another petition on behalf of petitioner and
Trupin was filed in this Court at docket No. 26819-92 contesting
liabilities determined for 1984, 1985, and 1986. On June 1,
1993, a stipulation of settled issues was filed with respect to
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