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began an examination of these partnerships at some point in the
mid-1980's as part of a national project focusing on the various
partnerships of the Greenberg brothers.
Respondent issued notices of final partnership
administrative adjustments (FPAA's) to the tax matters partner
(TMP) for each of the partnerships determining adjustments to
partnership items for the following partnership taxable years:
Partnership
Docket No. FPAA Date Taxable Years Petition Date
22780-91 July 8, 1991 1983-86 Oct. 7, 1991
621-92 Oct. 15, 1991 1984-89 Jan. 8, 1992
At the time the petitions in these cases were filed the
principal place of business for each partnership was located at
Greenwich, Connecticut.
The Lockes were married and filed joint Federal income tax
returns for the years at issue. Mr. Locke's investment in these
partnerships was purchased only in his name. The Schedules K-1
issued by the partnerships were issued solely in the name of Mr.
Locke.
On April 7, 1992, Mr. Locke filed a petition in bankruptcy
with the U.S. Bankruptcy Court for the Southern District of New
York. Mr. Locke subsequently was granted a discharge by order of
2(...continued)
loss deductions based upon the alleged purchase of the motion
picture "The Terminator" starring Arnold Schwarzenegger, as well
as such films as "The Howling II", "Return of the Living Dead",
"Perfect Strangers", "A Breed Apart", and "Special Effects".
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