James R. and Susan B. Brickman - Page 2

                                        - 2 -                                         

                         1993     51,328          10,266                              
                         1994     32,269          6,454                               



               After concessions,1 the issue for decision is whether                  
          certain net operating losses (NOL's) are reduced under section              
          108 because of discharge of indebtedness income (COD income).2              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners, husband and            
          wife,  resided in Dallas, Texas, at the time they filed their               
          petition.                                                                   
               Petitioner James R. Brickman (James) invested, as a limited            
          partner, in Sovereign Partners V, Ltd., a Texas limited                     
          partnership (the partnership).  On or about May 23, 1984, the               
          partnership was formed to acquire a tract of land in Flower                 
          Mound, Texas, develop the land into residential lots, and sell              
          the lots to homebuilders (the project).  James had a 74.1-percent           
          limited partner interest in the partnership.  The interest in the           



               1  Respondent concedes the 1992 deficiency and the accuracy-           
          related penalties for all years in issue.                                   
               2  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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