-7- On March 7, 2005, respondent sent petitioner an FPAA determining adjustments to the above expenses. In the FPAA, respondent determined that In Touch had overstated its deductions for consulting fees, marketing expenses, professional fees, and amortization.8 Respondent also determined that the at-risk amounts of In Touch’s members must be reduced and that the capital contributed by In Touch’s members as of December 31, 2000, was $50,000. Tax Court Litigation On May 27, 2005, petitioner filed his petition for readjustment of partnership items. A trial was held in Oklahoma City, Oklahoma, on March 9, 2006. Petitioner, who was a member of In Touch during 2000, was the only witness who testified at trial on In Touch’s behalf. Petitioner, over respondent’s objection, attempted to introduce copies of seven promissory notes, each dated December 31, 2000.9 The promissory notes were as follows: 8 Respondent allowed In Touch’s startup costs of $11,408, consisting of meals and entertainment of $277, bank charges of $20, printing costs of $111, and rent of $11,000. Respondent recomputed In Touch’s allowable amortization expense deduction for 2000 ($11,408 x 7/60 = $1,331). 9 Petitioner also introduced a promissory note (Exh. 17-P) that he had executed in favor of In Touch. Respondent did not object to this exhibit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007