- 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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