- 2 - Arthur Willner (Willner) to dismiss for lack of jurisdiction as to him, based on Willner's contention that he is not a partner in the partnership known as Oceanic Leasing that is the subject of this proceeding, and the motion by Willner requesting leave to file a notice of election to participate. Willner concedes that we have jurisdiction over the partnership items of Oceanic Leasing, even though that entity was a sham and not a bona fide partnership. He contends, however, that the partnership losses claimed by him on his individual income tax return for 1986, under the names Oceanic Leasing VI and Oceanic Leasing XXXV and under the single Federal identification number of Oceanic Leasing, related to different partnerships. Use of the term "partnership" as singular or plural in this opinion is for convenience and does not have any legal significance with respect to the separateness or validity of any entity mentioned. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Factual Background Hardin's Oceanic Leasing C. Robert Hardin (Hardin) conducted a tax return preparation business in San Francisco, California, known as "The Tax Company". In 1985, Hardin commenced solicitation of clients to invest in partnerships engaged in equipment leasing transactions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011