-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:
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