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LB Partnership
In 1983, petitioners and four other individuals formed a
partnership (the LB Partnership) to purchase a broodmare named La
Barbara. From 1983 through 1990, petitioners were general
partners of and each owned a 12.5-percent interest in the LB
Partnership.
In 1983, the LB Partnership purchased La Barbara, and La
Barbara was stabled in Kentucky. The record does not indicate
the purchase price of La Barbara.
Fred Hellman (Hellman) was the managing partner of the LB
Partnership. Hellman was responsible for maintaining the books
and records of the LB Partnership and for paying all expenses of
the LB Partnership.
The LB Partnership made decisions by majority vote of all
six partners.
From 1983 through 1990, the LB Partnership bred La Barbara
with a number of stallions. The record does not indicate the
number of times in each year the partners attempted to breed La
Barbara, and the record does not indicate how many foals were
produced by La Barbara.
The schedule below summarizes for 1983 through 1988 the net
profits and losses allocated from the LB Partnership to
petitioners:
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Last modified: May 25, 2011