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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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Last modified: May 25, 2011