-416- It is determined that during the tax year 1978 you failed to report your distributive share of partnership income from the sources shown. Consequently, your taxable income is increased in the amount of $4,953.00. As Shown Below: T.C. Family Trust ($512.00) Everglades Trust No. 1 1,093.00 Everglades Trust No. 2 1,093.00 Everglades Trust No. 3 1,093.00 Everglades Trust No. 4 1,093.00 Everglades Trust No. 5 1,093.00 4,953.00 The notice of deficiency did not identify the partnership(s) generating the income determined in item 1h. In addition, although Kanter disputed this adjustment in his petition, he did not identify the underlying partnership. On June 13, 1994, respondent filed an amendment to answer which identified the $4,953 adjustment as “Partnership Income/Loss (Fuel Boss - Energy Management Systems)”. No evidence regarding this adjustment was offered by either party during the trial of these cases. After trial, on May 15, 1995, the parties submitted to the Court a stipulation of settlement addressing a number of the adjustments determined in the notice of deficiency for 1978. Paragraph 5 of the stipulation of settlement concerns item 1f from the notice of deficiency and states: “Notice of deficiency adjustment 1(f), ‘Schedule C--Income/Loss.’ The Court need notPage: Previous 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 Next
Last modified: May 25, 2011