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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.
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