T.C. Memo. 2001-151
UNITED STATES TAX COURT
INTERHOTEL COMPANY, LTD., TORREY HOTEL ENTERPRISES, INC., TAX
MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 13017-95. Filed June 22, 2001.
M and THEI were partners in IHCL, a limited
partnership formed in 1981 to hold interests in Landmark
and Gateway, two limited partnerships. Landmark and
Gateway were formed to construct, own, and manage
separate hotel towers of a San Diego resort complex.
Landmark and Gateway financed their hotel developments
using nonrecourse debt.
The IHCL partnership agreement provided that upon
liquidation, the proceeds would be distributed only to
those partners having positive capital accounts. The
partnership agreement did not require the partners to
* This Memorandum Opinion supplements our Opinion in
Interhotel Co., Ltd. v. Commissioner, T.C. Memo. 1997-449 (1997),
vacated and remanded without published opinion 221 F.3d 1348 (9th
Cir. 2000).
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