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6653(a) and 6661.1 The deficiency arose from respondent’s
determination that petitioner2 had a distributive share of
$827,968 in the partnership gain on the sale of a shopping mall
by Pecaris Enterprises (Pecaris), a partnership in which
petitioner has a 25-percent interest, to Coastal Investments Co.
(Coastal), a partnership in which he has a 90-percent interest.
We hold that petitioner's distributive share of partnership
gain that Pecaris realized on the sale of the Mall is $827,968,
the amount determined by respondent, although we arrive at that
destination by a somewhat different route than respondent would
have had us follow. We reject respondent's determination of the
additions to tax.
FINDINGS OF FACT
Some of the facts have been stipulated, and are so found.
The stipulation of facts and attached exhibits are incorporated
herein. When petitioners filed their petition, they resided in
Ohio.
1Unless otherwise identified, section references are to the
Internal Revenue Code in effect for 1988, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
2Marilyn Goudas has an interest in this case solely by
virtue of having filed a joint 1988 Federal income tax return
with her husband. Accordingly, all references to petitioner in
the singular are to Carl Goudas.
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