-415- affd. 930 F.2d 372 (4th Cir. 1991); Estate of Cook v. Commissioner, T.C. Memo. 1993-581. The Court further holds the Kanters are not entitled to deductions under section 162 for 1979 with respect to IRC’s claimed business expense deductions. IRC was not engaged in an active trade or business during 1979, as IRC’s activities fail to satisfy even the “in connection” with a trade or business standard of section 174. See Estate of Cook v. Commissioner, supra. Issue XIV. Whether Kanter Received Unreported Partnership Income During 1978 (STJ report at 145-146) FINDINGS OF FACT The notice of deficiency respondent issued to the Kanters for 1978 included as an attachment a Form 4549-B, Income Tax Examination Changes, and an accompanying schedule describing the changes determined in the notice. Item 1h, titled “Partnership Income” states:Page: Previous 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 Next
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