- 6 - 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 accordancePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011