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Federal income tax withheld listed was $394. The Tax Office of
W.J. Hoyt Sons Management Co. was listed as the return preparer
on the 1986 return.
The Schedules K-1, Partner’s Share of Income, Credits,
Deductions, etc., issued by SGE 1984-2 to petitioner and
Christopher for 1984, 1985, and 1986 list the following under the
area for partner’s name: “Christopher & Verna Doyel”.
In reviewing the 1984 return, the $30,270 loss surprised
petitioner because it was so large, but she did not ask any
questions about this deduction. Petitioner and Christopher
merely assumed that the losses would be large enough so that all
withheld income taxes would be refunded to them.
In 1985, petitioner and Christopher applied for a refund of
their 1981, 1982, and 1983 taxes in the amounts of $3,531,
$4,160, and $5,102, respectively.
On March 11, 1998, respondent mailed petitioner and her
husband two letters and reports explaining computational
adjustments made to their 1981, 1982, 1983, 1984, 1985, and 1986
returns as a result of adjustments made to the partnership
returns of SGE 1984-2 for 1981, 1982, 1983, 1984, 1985, and 1986.
These computational adjustments resulted from the Court’s opinion
in Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C.
Memo. 1996-515.
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