- 3 - year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. After concessions by both parties, the sole remaining issue for decision is whether certain Texas "rollback" taxes in the amount of $364,576.70 and attorney's fees in the amount of $2,500 comprising a portion of the "Other deductions" on the Schedule K attached to SLR's return may be applied in reduction of the amount realized on the disposition of real property, as asserted by J. Steve Anderson III (petitioner or Anderson), or were properly reclassified as deductions related to so-called portfolio income, see section 469(e)(1)(A)(i)(II); and section 1.469-2T(c)(3)(i), Temporary Income Tax Regs., 53 Fed. Reg. 5716 (Feb. 25, 1988), as determined by respondent. This case was submitted on a full stipulation of facts, and the facts as stipulated are so found. This reference incorporates herein the stipulation of facts and attached exhibits. SLR is a limited partnership, with its principal place of business located at 5809 NW Grand Boulevard, Suite C, Oklahoma City, Oklahoma, at the time the petition was filed. Background For its taxable year 1990, SLR was subject to the unified audit procedures of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat. 648-667, codified at sections 6221 through 6233. Anderson is its only general partner; he holds a 50.5 percent interest in SLR. Anderson isPage: 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