Alan H. Ginsburg and Estate of Harriet F. Ginsburg, Deceased, Alan H. Ginsburg, Personal Representative - Page 5

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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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