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name and address as Iron Hill Restaurant-Lounge Inc., 1108 S.
College Ave., Newark, Delaware 19713 (the restaurant's location).
The partner's EIN is shown as 23-2353924. However, the
partnership's name and address on the Schedule K-1 is I.H.R.L.,
Ltd., c/o 404 Arbour Dr., Newark, Delaware., with the EIN
previously given for Iron Hill Restaurant-Lounge Ltd. on the Form
1065. The Schedule K-1 indicates that the partner (Iron Hill
Restaurant-Lounge, Inc.) is not a general partner, that it is a
corporation, and that the partner's percentage of profit and loss
is "100%". The Schedule K-1 thus shows the partner's distrib-
utive share of ordinary income as $1,011.39.
Respondent's records show no returns filed for 1987 or 1988
for Iron Hill under either of the two EIN's shown on the
partnership return: 51-0290454 or 23-2353924. We find that no
such returns were filed for 1987 or 1988. Nor were income tax
returns filed from 1980 through the years in issue for R.E.P.,
Ltd., Real Estate Plus, or Ferry Associates.
MIT LTD Bank Account
Iron Hill funds were deposited in two bank accounts: MIT,
Ltd., and Wayanne, Ltd.4 The Wayanne account was used for
payroll, and is not here relevant. The restaurant proceeds not
4 At one point some restaurant proceeds were also deposited
in an account in the name of R.E.P. at First Federal, but that
was closed in or before 1985. The R.E.P. account at issue here
was located at Second National Federal Savings Bank.
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