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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 Ending
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