- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011