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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.
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Last modified: May 25, 2011