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1989 reported gross income includes their pro rata share of NPI’s
reported gross income, which equals $79,712 (66.7 percent of
$119,508).
For purposes of applying section 6501(e), we hold that the
Bensons’ reported gross income of $615,378 on their 1989 return,
which is itemized as follows:
Items of gross Amounts reported
income by the Bensons
Wages $103,372
Interest 2,505
Rental income 24,950
Royalties 166,872
Other income (NPI Salary) 100,000
Evelyn C. Hermsmeir 137,342
partnership
1120-S return of NPI 79,712
Baden Spiel Haus 625
partnership
Total 615,378
3. 25-Percent Omission
We hold that the Bensons omitted 72 percent14 of their
reported gross income in 1989; therefore, the 6-year period of
limitations applies to their 1989 tax year as provided by section
6501(e)(1)(A).
B. 1994
The parties contend that the Bensons omitted gross income in
1994 as follows:
14 $444,086 / $615,378 equals 71.641 percent.
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