John C. Vanderschraaf and Cornelia Vanderschraaf, et al. - Page 3

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
               After settlement of some issues, the primary issue for                 
          decision is whether the profit objective of certain partnership             
          investments should be measured at the partnership level or at the           
          individual partner level.                                                   

          Background                                                                  
               Many of the facts have been stipulated and are so found.               
          The entire trial record and the testimony and exhibits admitted             
          into evidence in our test case opinion in Krause v. Commissioner,           
          99 T.C. 132, 133-167 (1992), affd. sub nom. Hildebrand v.                   
          Commissioner, 28 F.3d 1024 (10th Cir. 1994), have been stipulated           
          as part of the trial record herein.  Krause involved limited                
          partnership investments that are closely related to the limited             
          partnership investments at issue herein.                                    
               Background and other general facts as they were found in               
          Krause that relate directly and indirectly to the partnership               
          investments involved herein we, by this reference, incorporate as           
          findings of fact in the instant cases.                                      
               Petitioners, John C. and Cornelia Vanderschraaf, resided in            
          Fountain Valley, California, at the time they filed their                   
          petitions.                                                                  






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