Investment Engineers, LTD., Robert S. McGlamery, A Partner Other than the Tax Matters Partner - Page 2

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            $123,000 for 1984.  In Investment Engineers, Ltd. v.                                          
            Commissioner, T.C. Memo. 1994-255, we concluded that the statute                              
            of limitations did not bar assessments pursuant to the FPAA.                                  
            Remaining for decision is whether the partnership is entitled to                              
            deductions claimed under section 174 in the amounts adjusted by                               
            respondent.  Unless otherwise indicated, all section references                               
            are to the Internal Revenue Code in effect for the years in                                   
            issue, and all Rule references are to the Tax Court Rules of                                  
            Practice and Procedure.                                                                       
                                           FINDINGS OF FACT                                               
                  Some of the facts have been stipulated, and the stipulated                              
            facts are incorporated in our findings by this reference.  The                                
            history of management of the partnership is set forth in T.C.                                 
            Memo. 1994-255.  Subsequent to that opinion, respondent filed a                               
            Motion to Appoint a Tax Matters Partner.  Robert L. Montelius,                                
            Jr. (Montelius), was appointed tax matters partner solely for the                             
            purpose of these proceedings.                                                                 
                  The partnership was formed in December 1982.  The promoter                              
            of the partnership was Gregory A. Knox (Knox).  Knox had a juris                              
            doctor degree, but was not admitted to any bar, and made his                                  
            living as a financial planner.                                                                
                  The partnership was created by a Limited Partnership                                    
            Agreement dated December 14, 1982.  The stated purpose of the                                 
            partnership was to engage in the business of research and                                     
            experimentation for the development of computer software in the                               

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