- 6 -
through 175, 201, and 302 (the 1983 partnerships). Series 162
was one of the Barrister partnerships organized in 1983.
Barrister was the general partner and tax matters partner of
Series 162.4
All of the Barrister partnerships were similar to each
other, having all been organized to acquire and exploit literary
and computer program properties (properties), which were
purchased or leased, directly or indirectly, from corporations
owned or controlled by Cohen. With respect to Series 162,
Universal acquired the properties from several publishers and
then leased these properties to Series 162.
On behalf of Series 162, Cohen arranged to have "services
contractors" publish, distribute, and sell the products to be
produced with the properties Universal leased to Series 162. In
most cases, the services contractors were affiliates of the
publishers of the books or the computer programs. For example,
Confucion Press, Inc., a subsidiary of the publisher, Richard
Gallen & Co., Inc., was expected to serve as a services
4
Series 162 is subject to the unified audit and litigation
procedures of secs. 6221-6233. Those provisions, sometimes
referred to as the TEFRA procedures, were enacted as part of the
Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.
97-248, sec. 402(a), 96 Stat. 648, and provide a method for
adjusting partnership items in one unified partnership
proceeding, rather than in separate proceedings with the
partners. Maxwell v. Commissioner, 87 T.C. 783, 787 (1986); H.
Conf. Rept. 97-760, at 600, 604 (1982), 1982-2 C.B. 600, 662,
664.
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