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George Tomas Rhodus, for petitioners.
James E. Archie, for respondent.
MEMORANDUM OPINION
WHALEN, Judge: These nine consolidated cases are
before the Court to decide Petitioners' Motion for Summary
Judgment filed pursuant to Rule 121, Tax Court Rules of
Practice and Procedure. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Each of the subject cases is a partnership action,
as defined by Rule 240(b)(2), that involves a limited
partnership. Respondent issued a notice of final
partnership administrative adjustment (FPAA) to each
partnership stating that an adjustment to the partnership's
income would be made due to an "IRC Section 752(b)
Distribution". Unless stated otherwise, all section
references are to the Internal Revenue Code, as amended and
in effect during 1989. The adjustment determined by
respondent in each case is as follows:
Partnership Adjustment
Dakotah Hills Offices Ltd. Partnership $385,519
Pavilion II Ltd. Partnership 432,084
Copper Crest I Ltd. Partnership 181,371
Dakotah Hills Retail Ltd. Partnership 972,812
Club Carmel Ltd. Partnership 234,902
Pio Decimo II Ltd. Partnership 2,685,926
Ina Thornydale Ltd. Partnership 480,813
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