Gary W. McDonough - Page 10




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                2 This partnership loss was further broken down as                    
               follows:  Ordinary loss of $59,179 and a special                       
               allocation deduction of $33,782 for legal fees.                        
          Petitioner never asked the Hoyt organization to let him see any             
          record relating to a partnership for which petitioner claimed               
          losses for 1988 and 1991, and petitioner never contacted the Hoyt           
          organization to ask questions or request records substantiating             
          the amounts of partnership losses reported on his 1989 and 1991             
          tax returns.                                                                
               Petitioner’s 1988, 1989, 1990, and 1991 tax returns included           
          Forms 8271, Investor Reporting of Tax Shelter Registration                  
          Number, listing a number of tax shelters including TBS (for 1988,           
          1989, and 1990), DSBS 87-C (for 1988 and 1990), and TBS 89-1 (for           
          1989, 1990, and 1991).  Petitioner’s 1991 return also included a            
          one-page document that he entitled “Material Participation                  
          Statement”.  Petitioner signed that statement on September 30,              
          1992, asserting therein that he had spent 145 hours in 1991                 
          materially participating in a business activity of his named                
          “Gary McDonough Co.”  Petitioner’s 1991 return also included two            
          Schedules F, Profit or Loss from Farming, reporting farm income             
          of $1,800 and $23,294 from a “SALE OF COW” and “BREEDING VALUE              
          PRODUCTION AND SALES”, respectively, and reporting no related               
          farm expense.  The $23,294 stemmed from petitioner’s                        
          participation in TBS 89-1 and appeared on his 1991 Schedule K-1,            
          Partner’s Share of Income, Credits, Deductions, Etc., from TBS              







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