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and conclusions of a factual nature, they are based upon
materials forming a part of the record.
During the years at issue, Robert W. Quick (Robert) was a
limited partner in Water Oaks, Ltd. (Partnership), a Florida
limited partnership. (Robert died on or about May 23, 1997,
shortly after the petition was filed. On July 11, 1997,
petitioners moved, pursuant to Rule 63, to substitute Esther P.
Quick as the personal representative for the Estate of Robert W.
Quick. Petitioners' Motion for Substitution of Party was granted
by Order of the Court dated July 15, 1997, and the caption was
amended accordingly.) At all relevant times, the Partnership was
a so-called TEFRA partnership whose tax treatment is determined
under the unified partnership audit and litigation provisions
(subchapter C of chapter 63) added by the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 648.
The Partnership owned and operated the Water Oak Estate
Mobile Home Park (Park) in Lady Lake, Florida. During the years
at issue, a portion of the lots located in the Park was leased to
mobile home owners, while the remaining lots were in the process
of development.
Petitioners reported their distributive share of losses from
the Partnership as passive losses on their joint Forms 1040, U.S.
Individual Income Tax Return, for 1987 and 1988. (The record
does not reflect the extent of such losses for those years.)
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