- 3 - FINDINGS OF FACT Petitioners lived in Richmond, Virginia, when they filed their petition in this case. From 1998 through at least 2001, petitioners were involved in transactions with Anderson Ark & Associates,2 pursuant to which they purported to create a TEFRA partnership and purportedly incurred a liability so as to create basis and cause large losses to be shown on their income tax returns for several years. Petitioners offset their income with net operating losses of $183,455 for 2000 and $110,367 for 2001 from the purported partnership. They also claimed a loss of $32,065 on the Schedule E attached to their 2001 Federal income tax return. Petitioners claimed itemized deductions of $31,893 for 2000 and $21,875 for 2001, including medical and dental expenses, real estate taxes, other taxes, home mortgage interest, cash contributions, noncash contributions, and miscellaneous expenses. Respondent audited petitioners’ returns for 2000 and 2001 and determined deficiencies and additions to tax. Respondent also determined that petitioners overreported capital gain income by $9,894 for 2001. Petitioners provided no documents or other evidence to support their claimed deductions or to show that respondent’s 2 An organization named Anderson Ark & Associates was engaged in facilitating income tax evasion and bankruptcy fraud. See United States v. Anderson, 391 F.3d 970, 972 (9th Cir. 2004).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011