Oceanic Leasing, Douglas F. Spaulding, Tax Matters Partner - Page 11

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          settlement involves allowing investors to deduct theft losses               
          incurred as a result of their dealings with Hardin.  Willner                
          receives no benefit from the settlement.  On October 4, 1995,               
          Willner filed a Motion for Leave to File Notice of Election to              
          Participate in order to contend that he was not a partner in the            
          partnership that is the subject of this proceeding, and on                  
          January 11, 1996, he filed his jurisdictional motion.                       
                                     Discussion                                       
               "[M]ushrooming administrative problems experienced by the              
          Internal Revenue Service in auditing returns of partnerships,               
          particularly tax shelter partnerships with numerous partners",              
          led to the enactment of the TEFRA partnership proceedings in                
          1982.  Boyd v. Commissioner, 101 T.C. 365, 368 (1993).  The                 
          purpose of the new procedures was to provide a method for                   
          uniformly adjusting items of partnership income, loss, deduction,           
          or credit, without the necessity of separate proceedings for each           
          partner.  Id. at 369; Maxwell v. Commissioner, 87 T.C. 783, 787             
          (1986).  Willner here seeks to avoid the normal consequences of             
          our determination in this action, which would be an assessment              
          against him based on disallowance of all partnership losses                 
          claimed by him on his 1986 return under the name and EIN of                 
          Oceanic Leasing.  See secs. 6225, 6229(d) and (e), 6231(a)(6);              
          Sente Inv. Club Partnership v. Commissioner, 95 T.C. 243, 248-249           







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