- 22 - the effective and efficient enforcement of internal revenue laws. Consequently, the partnership items of such partner, arising in a partnership taxable year ending on or before the last day of the taxable year of the partner for which a deficiency notice based upon an indirect method of proof is mailed to the partner, shall be treated as nonpartnership items as of the date on which the deficiency notice is mailed. Therefore, respondent was not required to issue National Land Bank an FPAA before mailing the statutory notice of deficiency to petitioner. D. Miroyal Income At trial, petitioner asserted the Fifth Amendment privilege and refused to admit or deny whether she provided real estate services in 1999 and 2000. Similarly, petitioner refused to confirm or deny whether she managed real property in 1999 and 2000 on the same Fifth Amendment reasoning. Respondent for lack of substantiation disallowed Miroyal’s claimed deductions for 1999 as follows: $20,165 for repairs and maintenance, $15,696 of interest, and $14,107 of other deductions (i.e., insurance $5,913, miscellaneous $6,351, and utilities $1,843). Petitioner signed Miroyal’s 1999 and 2000 Federal tax returns, naming herself the tax matters partner for 2000, yet she provided no receipts or records but provided only a typed list showing the total amounts Miroyal allegedly expended on thePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011