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MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent, for the taxable year ended
June 28, 1988, mailed separate notices of final partnership
administrative adjustment to the tax matters partners of Parker
Properties Joint Venture (Parker Properties) and Twenty Mile
Joint Venture (Twenty Mile). In these notices, respondent
increased Parker Properties' and Twenty Mile's incomes by
unreported cancellation of indebtedness income of $3,419,963 and
$1,395,492, respectively.
The issues remaining for our consideration are: (1) Whether
the partnerships realized income from cancellation of
indebtedness; and, if so, (2) the amount of such income.
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, unless otherwise
indicated.
FINDINGS OF FACT2
Background
At the time the petitions were filed, Parker Properties’ and
Twenty Mile’s principal places of business were in Parker,
Colorado.3
2 The stipulations of fact and the exhibits are incorporated
by this reference.
3 The petition of Philip D. Winn & Associates, Inc. (PDW&A),
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