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Springs’ 1991 Federal partnership income tax return of
$2,321,014.
On L&C Springs' 1991 Federal partnership income tax return,
it was indicated that, because "the apartment buildings in Miami
Springs, Florida, are in bankruptcy" the records necessary to
report L&C Springs' net operating losses and other expenses could
not be located, and therefore no net operating losses or
depreciation expenses were reported and deducted relating to the
L&C Properties. It does not appear from the record that L&C
Springs ever filed an amended 1991 Federal partnership income tax
return claiming any 1991 net operating losses, accrued interest,
or depreciation expenses relating to the L&C Properties.
The following schedule reflects net losses and related
interest and depreciation expenses relating to the L&C Properties
as claimed by L&C Springs for 1987 through 1990.
As Claimed By L&C Springs
Income Interest Depreciation
Year (Loss) Expense Expense
1987 $(278,646) $(250,075) $(164,855)
1988 (328,373) (254,413) (168,350)
1989 (350,570) (264,858) (167,707)
1990 (301,033) (261,961) (167,722)
On audit for 1987, not now before the Court, respondent, on
April 5, 1991, issued an FPAA to L&C Springs charging L&C Springs
with $2,250,000 in ordinary income on the ground that L&C Springs
effectively abandoned to Tanglewood its ownership interest in the
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