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1990 and 1991, and (2) whether petitioner is entitled to a
foreign tax credit of $55 for taxable year 1990.
When called for trial, the parties did not call any
witnesses or present any evidence, but they offered a stipulation
of facts and requested the Court to set dates on which to file
briefs. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Cheney, Washington, at the time the petition was filed in this
case.
For the years in issue, petitioner listed his occupation as
a college professor in his 1990 and 1991 Federal income tax
returns. In 1988, petitioner had purchased limited partnership
interests in Intelligent Systems - Master Limited Partnership
(Intelligent Systems), a partnership that was publicly traded on
the American Stock Exchange. Intelligent Systems, a company that
designs, manufactures, and markets microcomputer-related
products, had converted from a corporation to a master limited
partnership on December 31, 1986. The master limited partnership
was subsequently converted back to a corporation on November 29,
1991. In 1990 and 1991, petitioner's share of the net ordinary
losses suffered by Intelligent Systems was $28,666 and $20,340,
respectively. Petitioner deducted these losses on his 1990 and
1991 Federal income tax returns.
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