- 10 - In short, respondent fails to consider the highly unusual facts and circumstances of this case. Neither party was required to contribute cash for the purchase of the 70-Acre Tract. The gain from resale of part of the 70-Acre Tract was realized on the same day it was purchased. Documents were executed in the name of only one partner for the sake of administrative convenience. State Savings was purposefully recognized as a partner by BCI in consideration of the performance of a valuable service (i.e., making credit available for the transaction). Accordingly, we hold that BCI and State Savings formed a partnership valid for tax purposes. As a result, the partnership properly allocated 50 percent of the gain realized from the sale of the 25-Acre Tract to State Savings. We have considered all other arguments made by petitioner and respondent and found them to be either irrelevant or without merit. To reflect the foregoing, Decision will be entered for petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011