- 2 - section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the sole issue for decision is whether Booth Creek Investment, Inc., and State Savings and Loan Association of Lubbock formed a valid partnership for tax purposes. We conclude that they did. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, the principal place of business of 70 Acre Recognition Equipment Partnership was in Dallas, Texas. Booth Creek Investment, Inc. (BCI), was a corporation formed under Texas law. Its primary activity was the purchase of real estate for immediate resale. BCI participated in the booming Texas real estate market of the early 1980's, and it executed transactions quickly and frequently. BCI engaged in numerous joint purchases of real estate, and written partnership agreements were not always executed. In 1982, BCI became interested in purchasing approximately 70 acres of real estate (the 70-Acre Tract) from Recognition Equipment Inc. (REI). On December 23, 1982, BCI and REI entered into an agreement entitled "CONTRACT OF SALE" whereby BCI agreed to purchase, and REI agreed to sell, the 70-Acre Tract. Consistent with its past investment strategy, BCI intended to quickly develop and sell the property for substantial profit.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011