Eugene A. Sanders - Page 6

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               Before his Hoyt investment, petitioner had always prepared             
          his own tax returns.  As a Hoyt investor, petitioner chose to               
          have his tax returns prepared by Laguna Tax Service, a Hoyt                 
          organization.                                                               
               On April 15, 1990, petitioner filed a 1989 Federal income              
          tax return and reported wage and business income of $10,898 and             
          $95,674, respectively.  Durham issued petitioner a Schedule K-1             
          for the period ending September 30, 1989, which reported $81,440            
          as petitioner’s distributive share of Durham’s ordinary loss.  On           
          a Schedule E, Supplemental Income and Loss, attached to his 1989            
          return, petitioner reported a partnership loss of $81,440.                  
               During 1991, petitioner claimed and received refunds of                
          $14,607 and $16,998 for the taxable years 1987 and 1988,                    
          respectively, as a result of carrying back the 1989 loss from               
          Durham to these prior taxable years.                                        
               In a notice of beginning of administrative proceeding (NBAP)           
          dated February 19, 1991, respondent notified petitioner that                
          Durham’s 1989 taxable year would be examined.                               
               On April 29, 1991, petitioner filed a 1990 Federal income              
          tax return which reported business income of $52,941.  Durham               
          issued petitioner a Schedule K-1 for the period ending September            
          30, 1990, which reported $175,560 as petitioner’s distributive              









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