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Breeding Serv. 1989-1, J.V. v. Commissioner, docket No. 14712-95.
The decision for 1989 ordered and decided the following:
Partnership Item As Reported As Determined
Depreciation expense $1,056,720 -0-
Depreciation after 1986 1,056,720 -0-
The decision for 1991 ordered and decided the following:
Partnership Item As Reported As Determined
Farm income -0- -0-
Depreciation expense $555,199 -0-
Board expenses 1,983,470 -0-
Loss to drought 237,325 -0-
Interest expense -0- -0-
Net self-employment income (2,750,837) -0-
Other deductions 14,578 -0-
Gain under section 1231 11,686 -0-
Guaranteed payments -0- -0-
Respondent determined initially that these decisions
increased petitioner’s 1989 and 1991 income by $32,225 and
$100,241, respectively. On May 13, 2002, respondent reflected
those increases by assessing against petitioner $8,943 and
$28,347 of deficiencies for 1989 and 1991, respectively, as
computational adjustments under section 6231(a)(6). On May 26,
2004, respondent issued to petitioner the relevant affected items
notices of deficiency; those notices stated that petitioner was
liable for the disputed accuracy-related penalties as determined
on the basis of the deficiencies assessed as computational
adjustments. On September 1, 2004, respondent notified
petitioner that respondent had revised his computations of the
increases to petitioner’s 1989 and 1991 income, and thus the
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