- 2 - adjustments to L&C Springs Associates’ (L&C Springs’) 1988, 1989, and 1990 Federal partnership income tax returns, as follows: Respondent's Partnership Adjustments Income On Discharge Interest Depreciation Year Of Indebtedness Expense Expense 1988 $2,250,000 $(254,413) $(168,350) 1989 2,250,000 (264,858) (167,707) 1990 2,250,000 (261,961) (167,722) Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The above $2,250,000 in income that respondent charged to L&C Springs in respondent's FPAA for each of the years 1988, 1989, and 1990 is the same item of income and relates to respondent's contention that L&C Springs' ownership interest in two apartment complexes (the L&C Properties) through a Florida land trust was effectively abandoned or terminated in either 1988, 1989, or 1990, triggering, for Federal income tax purposes, a sale or exchange of L&C Springs' interest in the L&C Properties. Respondent's primary position is that L&C Springs' ownership interest in the L&C Properties should be treated as having been terminated as of the end of October of 1990. Alternatively and only as a protective measure, respondent contends that L&CPage: Previous 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