Oceanic Leasing, Douglas F. Spaulding, Tax Matters Partner - Page 2

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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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