- 16 - the partnerships for federal income tax purposes, provided that a reasonable basis exists for that return position. In the event that the Internal Revenue Service declines to issue a determination letter or ruling on the abandonment issue or Investors’ attorneys withdraw the request after mutual agreement with the Trustee, the Trustee may file a motion pursuant to 11 U.S.C. � 505 (b) for a prompt audit of the partnerships’ tax returns. Ultimately, the trustee entered into the agreement with the investors, and the agreement was approved by the Bankruptcy Court. The record does not disclose what action, if any, was taken to seek a ruling from the Internal Revenue Service as contemplated in the passages of the agreement, quoted above, or what action, if any, was taken by the Internal Revenue Service. The Form 1065, U.S. Partnership Return of Income, filed on behalf of Dakotah Hills for calendar year 1989 includes balance sheets as of the beginning and end of the year on Schedule L. Line 5 of Schedule L includes the following “Other current assets”: Beginning Ending Notes receivable--investors $192,400 $192,400 Line 12 of Schedule L includes the following “Other assets”: Beginning EndingPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011