T.C. Memo. 1998-198
UNITED STATES TAX COURT
GREENBERG BROTHERS PARTNERSHIP #12,
a.k.a. LONE WOLF MCQUADE ASSOCIATES, AND
RICHARD M. GREENBERG, TAX MATTERS PARTNER, Petitioner
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22780-91. Filed May 28, 1998.
Thomas E. Redding and Sallie W. Gladney, for participants
Herman M. and Gloria R. Nirschl.
Joseph F. Long and Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge: This case is before the Court
on participants Herman M. and Gloria R. Nirschl's (the Nirschls)
motion to dismiss for lack of jurisdiction. The underlying
dispute arises from the Nirschls' interest in Greenberg Brothers
Partnership #12, a.k.a. Lone Wolf McQuade Associates (Lone Wolf
or the partnership). The parties agree that for the partnership
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