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reported a total ordinary loss from trade or business in 1995 of
$2,941,054. On their 1995 Form 1040, U.S. Individual Income Tax
Return, petitioners reported the losses of $4,087,725 and
$2,941,054 from NASM and FAP, respectively, on the attached
Schedule E, Supplemental Income and Loss, Statement 15, Income or
Loss From Partnerships and S Corporations. Petitioners reported
total net losses on their Schedule E of $3,045,269.
Extensions of Period To Assess Tax
Respondent examined the 1995 Form 1065 of UK Lotto. UK
Lotto and respondent entered into six consecutive Forms 872-P,
Consent to Extend the Time to Assess Tax Attributable to
Partnership Items, for partnership items relating to UK Lotto’s
1995 tax year. The last Form 872-P executed on behalf of UK
Lotto and respondent for the taxable year 1995 extended the
period to assess any Federal income tax attributable to
partnership items to any time on or before December 31, 2003. On
April 25, 2003, respondent sent a letter to the representative
for UK Lotto stating that respondent accepted the 1995
partnership return as filed. Respondent did not conduct any more
TEFRA partnership proceedings.
In addition, petitioners and respondent executed nine
consecutive Forms 872, Consent to Extend the Time to Assess Tax,
for petitioners’ 1995 taxable year. The last Form 872 extended
the period to assess any Federal income tax to any time on or
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Last modified: May 25, 2011