Mack v. Comm'r

2016 T.C. Memo. 229, 112 T.C.M. 671, 2016 Tax Ct. Memo LEXIS 227
CourtUnited States Tax Court
DecidedDecember 19, 2016
DocketDocket No. 7186-14
StatusUnpublished

This text of 2016 T.C. Memo. 229 (Mack v. Comm'r) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mack v. Comm'r, 2016 T.C. Memo. 229, 112 T.C.M. 671, 2016 Tax Ct. Memo LEXIS 227 (tax 2016).

Opinion

WALTER S. MACK, JR. AND CONSUELO C. MACK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mack v. Comm'r
Docket No. 7186-14
United States Tax Court
T.C. Memo 2016-229; 2016 Tax Ct. Memo LEXIS 227; 112 T.C.M. (CCH) 671;
December 19, 2016, Filed

An appropriate order will be issued granting respondent's motion, and decision will be entered under Rule 155.

In 2011 P-H was a partner of a New York partnership, which reported P-H's distributive share of partnership income as $479,743. On their timely filed 2011 tax return, Ps reported only $75,000 of the income from P-H's partnership. Ps contend that P-H's fiduciary duties under State law required him to use the remainder to pay partnership expenses to keep the firm from failing.

Held: Ps are liable for income tax on P-H's full distributive share of partnership income for 2011. Any payment of partnership expenses by P-H was a contribution to capital, and he can deduct his share of the partnership's expenses.

Held, further, Ps are liable for an accuracy-related penalty for an underpayment attributable to a substantial understatement of income tax for their failure to report partnership income.

*227 Walter S. Mack, Jr., and Consuelo C. Mack, for themselves.
Shawna A. Early, for respondent.
GUSTAFSON, Judge.

GUSTAFSON
MEMORANDUM OPINION

GUSTAFSON, Judge: Pursuant to section 6212(b)(1),1 on December 23, 2013, the Internal Revenue Service ("IRS") issued to petitioners Walter S. Mack, Jr., and Consuela C. Mack a notice of deficiency, which determined for 2011 a deficiency in tax of $140,302 and an accuracy-related penalty of $28,060 under section 6662(a). The Macks filed a timely petition under section 6213(a) for redetermination of the deficiency and the penalty.

The case is before the Court on a motion for summary judgment filed by respondent, the Commissioner of the IRS, which the Macks have opposed. The sole issue raised by the petition2 is whether, as the Macks contend, Mr. Mack's otherwise taxable income from his partnership is reduced by his alleged obligation to make expenditures on behalf of the partnership. We hold that it is not, and we will grant the Commissioner's motion.

Background

For purposes of the Commissioner's motion for summary judgment under Rule 121, we assume correct the facts asserted by the Macks, as well as facts demonstrated by the Commissioner that the Macks did not dispute.3

Income from DRKM

Mr. Mack is an*228 attorney admitted to practice law in the State of New York, and he is a partner in the firm of Doar, Rieck, Kaley and Mack ("DRKM"). The notice of deficiency reflects, and the Macks do not dispute, that in 2011 two DRKM entities4 issued Schedules K-1, "Partner's Share of Income, Deductions, Credits, etc.", that reported Mr. Mack's share of partnership income (i.e., partnership revenue over expenses) as $18,357 and $461,386, totaling $479,743. It was then incumbent on Mr. Mack to reflect that on his tax return.

DRKM's "negative capital"

However, Mr. Mack alleges that, in the wake of the 2008 recession, other partners at DRKM could not cover their shares of the firm's expenses and that, as a result, the firm had gone into "significant negative capital". Mr. Mack felt that it was his fiduciary obligation under New York partnership law5 to cover other partners' partnership expenses. Mr. Mack claims that his DRKM "capital account bore no relationship to the financial condition of the partnership, and what little money was available to * * * [Mr. Mack] was used to absorb expense [sic] that normally would have been expenses of the firm." Mr. Mack does not allege that any partnership expenses*229 were omitted from the partnership's returns and Schedules K-1.

Advice from tax professionals

Because the available money had allegedly not been paid out to Mr. Mack but had been used to pay firm expenses, Mr. Mack evidently felt it should not be treated as income to him. But according to Mr. Mack,

When I sought the advice of the firms' accountants and tax preparers, I was in essence told that the tax law was unfair and unjust under these circumstances, and my options were to dissolve the firm, take all the capital in the firm to pay my taxes and move on, and let my partners fend for themselves, and the employees go on unemployment. When I discussed [m]y obligations under New York State Partnership Law to act as a fiduciary to my partners, I was told to be prepared to face the consequence of that decision as I am now, that the Respondent would likely be deaf to the financial realities of the firm and not respect the state law fiduciary partnership duties.

That is, the tax professionals told Mr.

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Cite This Page — Counsel Stack

Bluebook (online)
2016 T.C. Memo. 229, 112 T.C.M. 671, 2016 Tax Ct. Memo LEXIS 227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mack-v-commr-tax-2016.