Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 358

                                                -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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