-5-
showed a net loss of $276,560,5 which was allocated to its
members as follows:
Partner Share of loss
Lloyd Gilbert $30,000
David England 121,560
Mark Hanna -0-
Jim Coates 25,000
Abraham Joseph 50,000
Reebud Resources 50,000
Total 276,560
Disputed Adjustments
On July 24, 2002, respondent commenced an examination of In
Touch’s 2000 partnership return by mailing both an appointment
letter and an Information Document Request (IDR) to petitioner.
On September 9, 2002, respondent issued a second IDR to
petitioner. Among other things, the IDRs requested documentation
to substantiate the consulting fees, marketing expenses,
professional fees, and startup expenditures claimed on In Touch’s
2000 return.
With respect to the consulting fees, respondent requested
invoices and other documentation substantiating payment dates and
detailing the services provided to In Touch. In response, In
Touch produced Letters of Understanding (Letters) dated November
10, 2000, with respect to Beverly Stool, Jeff Giddings, and Gene
5 In Touch reported total income of $1,000 and total
deductions of $277,560 on its 2000 partnership return.
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Last modified: November 10, 2007