- 2 -2 Partnership (ASA) a notice of final partnership administrative adjustment (FPAA) that reflected adjustments to ASA's partnership return for taxable years which ended on May 31, 1990, May 31, 1991, December 31, 1991, and June 1, 1992. On December 24, 1996, AlliedSignal Inc. (AlliedSignal), ASA's tax matters partner, petitioned the Court to redetermine respondent's adjustments to partnership items. ASA was created by AlliedSignal, AlliedSignal Investment Corp., Barber Corp. N.V., and Dominguito Corp. N.V. The primary issue for decision is whether these corporations formed a valid partnership for Federal income tax purposes. We hold that they did not. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. On the date AlliedSignal filed the petition, ASA had no principal place of business because it had previously ceased operations. I. AlliedSignal and the Merrill Lynch Proposal AlliedSignal, a Delaware corporation, is a manufacturing company that produces aerospace and automotive products. It was formed in September 1985 when Allied Corp. merged with The Signal Companies, Inc.Page: 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