Jerry and Patricia A. Dixon, et al. - Page 55

                                       - 18 -                                         

          $95,028.  Neither petitioners nor respondent have been able to              
          locate a copy of the Thompsons’ 1982 tax return.  The 3-year                
          period of limitations under section 6501 expired with no action             
          by respondent concerning the Thompsons’ 1982 tax return.                    
                                        1983                                          
               The IRS received the Thompsons’ 1983 income tax return on              
          July 2, 1984.  The Thompsons reported no tax liability on that              
          return; they also reported Kersting interest expense deductions             
          of $67,620 as well as Bauspar deductions.                                   
                                        1984                                          
               Respondent received the Thompsons’ 1984 income tax return in           
          April 1985.  On that return, the Thompsons claimed Kersting                 
          interest expense deductions from two Kersting programs:  “Mahaio”           
          (Mahalo), in the amount of $4,320, and Federated Finance, in the            
          amount of $3,420.  The mortgage interest deduction included in              
          the return also included interest paid pursuant to the Bauspar              
          program.  The Thompsons paid $2,269 as tax shown on the return to           
          be owing.                                                                   
                                        1985                                          
               On their 1985 income tax return, the Thompsons reported                
          itemized deductions of $37,932 and reported adjusted gross income           
          of $22,507, resulting in zero taxable income.  Although the                 
          Thompsons did not claim any Kersting deductions on the return,              







Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  Next

Last modified: May 25, 2011