- 10 - Korchak’s Madison Recycling investment. Instead, he utilized a cash management account (cash management account) that he used to purchase all of the investments that he made.8 Petitioner became aware of Mr. Korchak’s Madison Recycling investment on February 2, 1986, when she and Mr. Korchak signed Form 872, Consent to Extend the Time to Assess Tax (Form 872), with respect to their taxable year 1982. That form stated in pertinent part: The amount of any deficiency assessment is to be limited to that resulting from any adjustment to: (A) the taxpayer’s distributive share of any item of income, gain, loss, deduction, or credit of, or distri- bution from Madison Recycling, (B) the tax basis of the taxpayer’s interest(s) in the aforementioned partner- ship(s) or organization(s) treated by the taxpayer(s) as a partnership, (C) any gain or loss (or the charac- ter or timing thereof) realized upon the sale or ex- change, abandonment, or other disposition of taxpayer’s interest in such partnership(s) or organization(s) treated by the taxpayer as a partnership, (D) items affected by continuing tax effects caused by adjust- ments to any prior tax return, and (E) any consequen- tial changes to other items based on such adjustment. In 1986, without consulting petitioner, Mr. Korchak pur- chased a majority interest in Riverside Polymer Systems, Inc. (Riverside), and ultimately invested approximately $700,000 in that company. In 1989, Riverside filed for bankruptcy. As a result of that bankruptcy proceeding, Mr. Korchak lost his entire 8It is not clear from the record whether the cash management account was held (1) at a bank or another type of financial institution and (2) in the joint names of petitioner and Mr. Korchak.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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