- 3 - the discussion that follows. Petitioners bear the burden of proof on all questions of fact. Rule 142(a). I. Background Petitioners resided in Seattle, Washington, when the petition in this case was filed. Petitioner is a lawyer specializing in corporate and international trade law with emphasis in tax planning and complex corporate transactions. Petitioner received an LL.M. (with emphasis in taxation) from New York University School of Law. Petitioners are calendar year taxpayers. II. Interest Payments Credited to Aldergrove's Bank Account A. Introduction 1. Aldergrove Aldergrove Investments Co. (Aldergrove), was a partnership between Grove Management Ltd. (GML), see infra sec. II.A.2., and petitioner. Aldergrove's principal place of business was on Anguilla (an island of the British West Indies). Aldergrove did not file a U.S. Partnership Return of Income for 1991. Petitioners did not report any income from Aldergrove for 1991. Pursuant to the Aldergrove partnership agreement, effective July 1, 1984, partnership interests and capital contributions were as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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