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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.
The issues to be decided in the instant case are: (1)
Whether petitioners must include in their income for taxable year
1987 a payment made to them during that year by the White-Sicard
Co. partnership (partnership); and (2) whether petitioners are
liable for the additions to tax provided by sections 6653(a)(1)
and 6661.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties’ stipulations are incorporated herein by
reference and are found accordingly.
At the time the petition in the instant case was filed,
petitioners resided in Hampton, New Hampshire.
During relevant periods, petitioner Leon Sicard (petitioner)
was in the real estate development business and was involved in a
number of partnerships.
Petitioner and Charles White formed the partnership on or
about June 1, 1983. In general, petitioner and Mr. White formed
the partnership to build the Seabury Condominiums (condominiums),
a 54-unit condominium complex in Hampton, New Hampshire. All
profits, losses, expenses, and liabilities of the partnership
were to be shared equally by petitioner and Mr. White. At all
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