- 34 -
Capital gain 492
distributions
Taxable refunds 29,327
Rents 36,156
Royalties 1,340
Other income (NPI Salary) 200,000
Evelyn Hermsmeir 100,620
partnership
Bensons’ share of 243,094
NPI income
Bensons’ share of 579
Baden Spiel Haus
partnership
Total 814,311
The Bensons have omitted more than 25 percent of their reported
gross income in 1994.18
Even assuming that the Bensons correctly calculated the
amount of reported gross income as $1,011,740, they have omitted
more than 25 percent of the reported gross income in 1994.19 We
hold that the 6-year period of limitations applies to the
Bensons’ 1994 tax year as provided by section 6501(e)(1)(A).
III. Conclusion
In conclusion, we hold that the Bensons omitted from gross
income amounts that exceed 25 percent of their reported gross
18 $337,092 / $814,311 equals 41.396 percent.
19 $337,092 / $1,011,740 equals 33.318 percent.
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