Taxpayers Contest Disallowance Of Partnership Losses.

CHARLES H. AND KATHLEEN L. MICHEL,

====== SUMMARY ======

Charles and Kathleen Michel contest the IRS's disallowance of partnership losses from Arrowhead Mountain Limited.

Period and Amount at Issue: 1984 -- $22,340; 1986 -- $7,101; 1987 -- $13,882

Code Section Classification: 731

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PETITION

Petitioners CHARLES H. AND KATHLEEN L. MICHEL hereby petition for a redetermination of the deficiency set forth by the Commissioner of Internal Revenue in his notice of deficiency [Form 5601] dated June 15, 1993, and as a basis for their case allege as follows:

1. Petitioners are individuals with legal residence now at 18242 Pamela Place, Villa Park, California 92667-2627. CHARLES H. MICHEL's Social Security No. is * * * . The return for the periods here involved was filed with the Office of the Internal Revenue Service at Fresno, California.

2. The notice of deficiency (a copy of which, including so much of the statement and schedules accompanying the notice as is material, is attached and marked Exhibit A) was mailed to the petitioner on June 15, 1993, and was issued by the Office of the Internal Revenue Service at Laguna Niguel, California.

3. The deficiencies as determined by the Commissioner are in income taxes for the calendar years 1984, 1986, and 1987, in the amounts of $22340.00, $7101.00, and $13882.00, respectively. The entire amounts for all three years are in dispute.

ASSIGNMENTS OF ERROR

4. The determination of tax set forth in the said notice of deficiency is based upon the following errors:

4.1. The Commissioner erred in disallowing Limited

4.2. The Commissioner erred in determining that the

4.3. The Commissioner erred in determining that the tax for

4.4. The Commissioner erred in determining that the

4.5. The Commissioner erred in determining that the tax for

4.6. The Commissioner erred in determining that the

4.7. The Commissioner erred in determining that the tax for

STATEMENT OF FACTS

5. The facts upon which the petitioners rely as the basis of the petitioners' case, are as follows:

5.1. The taxpayers are individuals and filed tax returns

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WHEREFORE, petitioners pray that this Court may hear the case and determine that there is no deficiency due from petitioners for the taxable years 1984, 1986, and 1987.

DATED: September 13, 1993

JANE BAUER

Jane Bauer, Attorney at Law

Charles H. and Kathleen Michel