- 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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