- 6 - 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 distributivePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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