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The above named partnership entity was terminated
under Regulation Section 1.708-1(b)(ii) on [date of
sale] when both the 84% [99% for Vacant Lands I through
V], CC&F Western Operations, L.P. (Federal
Identification Number 59-2994986), and the 16% [1% for
Vacant Lands I through V] partner sold their entire
interests in the partnership to an unrelated party.
Bellevue did not identify itself as having been sold to an
unrelated third party during 1990. Each partnership that was
conveyed attached, to its Federal income tax return, a Schedule
K-1 for each of its partners. On line B of the 12 Schedules K-1
of Western, the partnerships listed Western’s share of
partnership liabilities in the following amounts:
Bellevue $ 7,657,419
Cabot Plaza 0
Chatsworth 23,552,592
Diamond Bar 8,846,254
Issaquah 4,960,496
Mira Loma 0
Topanga 11,000
Vacant Land I 10,337,621
Vacant Land II 2,935,574
Vacant Land III 298,884
Vacant Land IV 1,866,711
Vacant Land V 9,492,939
Total $69,959,490
Neither the 1990 Federal income tax return of Western nor the
returns of the partnerships that were conveyed disclosed that the
third-party purchaser paid or assumed Western’s liabilities.
On October 14, 1997, more than 3 years but less than 6 years
from the date of filing of Western’s return, respondent sent the
FPAA to petitioner, determining that there was unreported gain on
the sale of the partnership interests.
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Last modified: May 25, 2011