- 5 -
returns; these losses were suspended pursuant to the provisions
of section 469.3
On December 30, 1990, petitioner conveyed his interest in
Bass Associates to Mr. Allingham. The written assignment
provided as follows:
WHEREAS, BASS Associates, a Connecticut general
partnership, was formed in December of 1986
("Partnership") consisting of the following partners
and their percentage ownership in said Partnership:
Fred L. Baker 20%
George D. Allingham 25%
Raymond Staron 45%
Bernard Staron 10%
WHEREAS, on December 31, 1986, the Partners d/b/a
BASS Associates purchased the land and buildings known
as 1835 Post Road East, Westport, Connecticut
("Property"), more particularly described on Schedule A
annexed hereto and made a part hereof; and
WHEREAS, the Property is subject to a first
mortgage in favor of Citytrust in the original
principal amount of $1,200,000 dated June 29, 1987 and
recorded in Volume 897 at Page 68 of the Westport Land
Records, as amended; and
WHEREAS, Assignor desires to sell, assign,
transfer and set over to Assignee all of his right,
title and interest in and to said Partnership and
Assignee agrees to purchase all of Assignor's right,
title and interest in said Partnership; and
NOW, THEREFORE, in consideration of the foregoing
recitals and of the mutual covenants, conditions and
agreements herein contained, the parties hereto do
hereby agree as follows:
3Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011