Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 6

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                 The partnership filed two Forms 1065, U.S. Partnership              
             Return of Income, for taxable year 1983.  The first return,              
             dated March 16, 1984, is signed by Mr. Caldwell in the                   
             space provided for "Signature of general partner".  The                  
             second return, dated April 9, 1984, is blank in the space                
             provided for the signature of the general partner, but                   
             is signed by Mr. Caldwell in the space provided for                      
             "Preparer's signature".  The two returns appear to be                    
             identical, except for the different placement of                         
             Mr. Caldwell's signature.  Each return claims an ordinary                
             loss of $28,429, which is composed of gross receipts of                  
             $58, a deduction for "lease rental" of $2,087, and a                     
             deduction for "distribution expense" of $26,400.  Attached               
             to both returns as "Schedule B" is a document entitled                   
             "Election  to Pass Investment Tax Credit From Lessor To                  
             Lessee". According to that document, the lessor of a laser               
             disk, worth $8,436,271, agreed to transfer the investment                
             credit on the laser disk to the partnership.                             
                  There are 27 Schedules K-1, Partner's Share of Income,              
             Credits, Deductions, Etc., attached to the partnership's                 
             1983 return.  The ordinary loss of $28,429 reported by the               
             partnership is allocated among the 27 partners.  In                      
             addition, the alleged fair market value of the laser disk,               
             $8,436,271, is allocated among the partners in accordance                






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