-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 not
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