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According to the agreement, Hardin, Calef, the Willners, and
Latta each were to contribute $75,000 to the partnership. In a
"First Amendment to Partnership Agreement" dated December 15,
1987, the capital contributions of the partners were increased to
$150,000. The contributions called for by the documents were
never made.
Willner received 1986 Schedules K-1 from Hardin. One
Schedule K-1 showed Oceanic Leasing VI at the Sausalito address.
The form reported his distributive share of loss as $1,617.
Willner also received a Schedule K-1 that showed Oceanic Leasing
XXXV at the Sausalito address and set forth his distributive
share of loss as $33,889. Both of the Schedules K-1 received by
Willner used the same EIN for Oceanic Leasing, to wit, 94-
2870681. When he received the Schedules K-1, Willner called
Hardin and asked about use of the same employer identification
numbers for Oceanic Leasing VI and Oceanic Leasing XXXV; he was
told that such use was not an error.
Willner prepared a Form 1040, U.S. Individual Income Tax
Return, for himself and his wife for 1986. On that Form 1040, he
claimed losses from Oceanic Leasing VI and Oceanic Leasing XXXV
in the amounts shown on the Schedules K-1 received by him,
showing the Oceanic Leasing EIN for each. He also attached to
his Form 1040 a Form 3468, Computation of Investment Credit,
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Last modified: May 25, 2011