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behalf of Miroyal for 1999. Miroyal claimed the following
deductions for 1999: (1) Repairs and maintenance, $20,165;
(2) interest, $15,696; and (3) other deductions, $14,107.
Attached to Form 1065 was a listing of these “other deductions”:
Insurance, $5,913; miscellaneous, $6,351; and utilities, $1,843.
During 1999 and 2000, Miroyal had two members. According to the
filed 1999 Form 1065 partnership tax return, each member, Sue
Taylor and Gerald Ricks, had a 50-percent interest. Sue Taylor
was designated as the tax matters partner on the calendar year
2000 Form 1065 Federal tax return.5 On its Form 1065, Miroyal
reported $2,380 of income for 1999. Petitioner’s Form 1065,
Schedule K-1 reflected her one-half distributive share of
Miroyal’s income in the amount of $1,190.
2. Taxable Year 2000
On April 19, 2001, petitioner filed Miroyal’s Form 1065 for
2000. Miroyal reported no income and no deductions for 2000.
In addition, petitioner attached Form 8275, Disclosure Statement,
referencing tax protester rhetoric claiming that Miroyal did not
have any income from any taxable sources. During 2000, the filed
Form 1065 partnership tax return indicated petitioner and Gerald
5 Miroyal’s Form 1065 for 1999 did not designate a tax
matters partner.
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