John Karason - Page 7




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          etc., for 2001 reported petitioner’s distributive share of KCP              
          losses was $31,689.7  Petitioner deducted his share of the losses           
          on his 2001 Federal income tax return.  From 1990 through 2003,             
          KCP did not generate a profit.                                              
          E.   The Audit                                                              
               In July 2004, respondent began the audit of petitioner’s               
          2001 return.  Respondent requested documentation from petitioner:           
          (1) Establishing that he owned the medical equipment including              
          purchase invoices, settlement sheets, and receipts; (2)                     
          substantiating the medical equipment’s FMV and depreciable basis;           
          (3) identifying bank accounts used in his medical equipment                 
          rental business including the bank account records; and (4)                 
          substantiating his adjusted basis in KCP.                                   
               To substantiate his basis in the medical equipment,                    
          petitioner provided a handwritten depreciation schedule for the             
          medical equipment titled “Depreciation 2005”8 with no supporting            
          documentation other than a copy of the promissory note for the              
          loan from Farmers Bank.  Petitioner also provided a Form 1099-              
          MISC, Miscellaneous Income, for 2001 from KCPI indicating it had            
          paid $16,662 to petitioner as rent for its use of the medical               
          equipment in 2001.  This form was not filed with the IRS.                   

               7 Schedule E loss of $31,337 + Schedule F loss of $13,933              
          ($45,270) x petitioner’s 70 percent ownership (.70) = $31,689.              
               8 Although the schedule was titled “Depreciation 2005”, it             
          listed the medical equipment depreciation deduction amounts from            
          2001 through 2006.                                                          





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