Sandy Lake Road Limited Partnership, J. Steve Anderson III, Tax Matters Partner - Page 3

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          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 is              




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