3 time that they filed their petition. The pertinent facts are summarized below. George Coward (petitioner) was an investor in Washoe Ranches #7 LTD. (the partnership), a limited partnership formed to engage in the business of breeding cattle. On December 20, 1978, Walter J. Hoyt III, as general partner, executed the Certificate and Articles of Limited Partnership for the partnership. Mr. Hoyt signed the limited partnership agreement on behalf of each of the limited partners including petitioner. The agreement stated that it was executed on January 1, 1978. The agreement was filed with the county of Washoe, Nevada. The partnership agreement provided that each limited partner would contribute cash to partnership capital in the amount set forth after his name. No amount was shown on the agreement after any limited partner's name. On December 28, 1978, petitioner made his first and only capital contribution to the partnership for the taxable year 1978 in the amount of $500. The partnership records show that capital contributions to the partnership from the six limited partners totaled $2,750 for that taxable year, and all of the contributions were made on December 28, 1978. On March 18, 1979, petitioner signed an agreement to purchase 12 units of the partnership for $30,000 as his interest. Under the terms of the partnership agreement, the general partner was not to contribute capital to the partnership. The general partner was responsible for managing the partnership. InPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011