4
RDB was a partner of Valley Cable, Ltd. (Valley Cable), a
Texas limited partnership, and Valley Cable was subject to the
unified audit and litigation procedures set forth in sections
6221 through 6233 (the TEFRA provisions) enacted by the Tax
Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,
sec. 402(a), 96 Stat. 648, and amended retroactively by the
Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 714(p)(1), 98
Stat. 494, 964. RDB was a pass-thru partner as defined in
section 6231(a)(9). Mr. Ray, Mrs. Dominguez, and Breese were
indirect partners of Valley Cable, as defined in section
6231(a)(10), due to their ownership interest in RDB.
In 1984, Mr. Ray, Mrs. Dominguez, and Breese were partners
in 6121 Joint Venture (6121), a general partnership, and RDB
transferred its interest in Valley Cable to 6121. R.D.B.
Investments II, Inc., was not a partner in Valley Cable during
the taxable years 1983 or 1984, and all references to R.D.B.
Investments II, Inc., refer to RDB with respect to the taxable
year 1983 and refer to 6121 with respect to the taxable year
1984. All actions taken in the name of R.D.B. Investments II,
Inc., were intended to be treated as the actions of RDB and 6121
with respect to the taxable years 1983 and 1984, respectively.
For convenience, we will refer to RDB, 6121, and R.D.B.
Investments II, Inc., as RDB.
Respondent designated Valley Cable a litigation project case
and assigned Valley Cable to a litigation project referred to as
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011