Interhotel Company, LTD., Torrey Hotel Enterprises, Inc., Tax Matters Partner - Page 1

                                 T.C. Memo. 1997-449                                  

                               UNITED STATES TAX COURT                                

                           MATTERS PARTNER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No.  13017-95.              Filed September 30, 1997.           

                    M and THEI were partners in IHCL.  IHCL was formed                
               in 1981 to hold interests in both PGL and PLH, which were              
               partnerships formed for the purpose of constructing,                   
               owning, and managing separate hotel towers of a resort                 
               complex located adjacent to the then-unbuilt San Diego                 
               Convention Center.  IHCL's partnership agreement provided              
               that upon liquidation, the liquidation proceeds would be               
               distributed only to those partners having positive                     
               capital accounts.  IHCL's partnership agreement did not                
               require the partners to restore any deficits in their                  
               capital accounts upon liquidation of the partnership.                  
                    In 1985, D agreed to invest $19.8 million in IHCL in              
               exchange for a 15-percent interest in IHCL, together with              
               a special allocation of 99 percent of IHCL's income and                
               losses.  Upon D's entry as a partner in IHCL, M withdrew               
               as a partner of IHCL, and THEI's interest in IHCL was                  

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011