- 4 - For purposes of our consideration of Petitioners’ Motion for Summary Judgment, the parties have not presented to the Court all of the documents that are pertinent to each of the nine cases. They have attached as exhibits to the stipulation several categories of documents that relate to each petitioner. These include the partnership agree- ment for each partnership, the U.S. Partnership Return of Income filed on Form 1065 by each partnership for taxable year ending December 31, 1989, and the FPAA issued by respondent to each partnership. They have also attached as exhibits to the stipulation certain other documents that relate to one of the partnerships, Dakotah Hills Offices Limited Partnership, in the case of docket No. 18955-93 (Dakotah Hills). As we read the Stipulation of Facts, the parties intend the Dakotah Hills documents as exemplars of the documents executed with respect to all of the cases. In the following discussion, we have focused on the facts in the Dakotah Hills case, and references to the partner- ship are references to Dakotah Hills. Dakotah Hills was formed by a group of four general partners, Mr. David Randall Jenkins, Ms. Renee Jenkins, Mr. Timothy Lee Shaftel, and the JNC Companies, an Arizona corporation. It was established on or about October 25, 1984, pursuant to the Uniform Limited Partnership Act of the State of Arizona, when the AgreementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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