ASA Investerings Partnership, Alliedsignal Inc., Tax Matters Partner - Page 2

                                        - 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