- 7 - to the Form 1120S, inter alia, was a Schedule K-1 for each shareholder. Petitioner’s Schedule K-1 reported his pro rata share as follows: Ordinary income of $27,489; charitable contributions of $2,499; investment interest income of $20; and depreciation of $1,690 (petitioner’s 2000 Schedule K-1). Petitioner timely filed a Form 1040EZ, Income Tax Return for Single and Joint Filers With No Dependents, for 2000. Petitioner did not report any of the items reported on petitioner’s 2000 Schedule K-1. In the notice of deficiency, respondent determined that petitioner failed to report shareholder interest income of $20 and shareholder ordinary income of $27,489. Respondent further determined that petitioner is liable for the accuracy-related penalty under section 6662(a) for a substantial understatement of tax. Petitioner timely filed a petition with the Court disputing the determined deficiency as well as the accuracy-related penalty. Paragraph 4 of the petition states as follows: The Notice of Deficiency was calculated based upon information reported on IRS Form 1120S filed on behalf of Union Machine, Inc., EIN 91-1688285, for the year ending 2000. The Form 1120S erroneously reported that I was a shareholder of Union Machine, Inc. I do not believe that I was a shareholder of Union Machine for the year ending 2000 (or for any part of the year ending 2000). The Schedule K-1, which the IRS has relied upon to determine the Notice of Deficiency, should not have been issued in my name. Accordingly, there is no basis for the Notice of Deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011