- 3 - The partnership agreement also contained the statement that “All decisions and management of the partnership shall be made by the majority of the shares held by the partners.” The partnership shares were in $1,000 units, with total capital investment set at $300,000. No partner possessed a majority percentage interest in Cascade. The partner with the largest percentage interest, as of the close of 1982, was William Smart. Cascade, a TEFRA1 partnership for Federal tax purposes, was formed as an investment vehicle for the 20 Price Waterhouse accounting partners to collectively invest as a limited partner in Wall Street Associates (Wall Street), a partnership not subject to the provisions of TEFRA. Wall Street issued a Schedule K-1 in Cascade’s name in care of Walsh. By a letter dated February 27, 1985, respondent notified Cascade of the commencement of an examination of Cascade’s 1982 and 1983 income tax returns under the unified partnership audit procedures of sections 6221-6233.2 The letter was addressed to “Cascade Partnership, Tax Matters Partner, Third Floor, Times Square Building, Seattle, Washington 98101.” An Information Document 1 TEFRA partnership provisions were added to the Code by the Tax Equity & Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. 2 All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011