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section 6621(c). All section references in this opinion
are to the Internal Revenue Code, as amended.
The deficiency determined by respondent is based upon
the following adjustment as described in the notice of
deficiency:
It has been determined that your distributive
share of the loss from the B.D.B. Properties
partnership which has an interest in the
Thunderbird Associates Ltd. partnership is
$(2,564.00) in lieu of $(31,255.00) which was
reported on your tax return for the taxable
year ending 1978. The Thunderbird Associates,
Ltd. partnership has been agreed to at the
partnership level.
As suggested above, one petitioner, Mr. Brody, held a
partnership interest in BDB Properties (BDB) and that
partnership held an interest in another partnership,
Thunderbird Associates, Ltd. (Thunderbird). Petitioners
reported a loss of $31,255 from BDB on their 1978 return
that was based upon BDB's share of the loss originally
reported by Thunderbird in the amount of $953,129.
Respondent determined that the correct amount of
Thunderbird's loss is $78,120 and, accordingly, adjusted
petitioners' return in the subject notice of deficiency
by reducing their share of the Thunderbird loss from
$31,255 to $2,564.
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