Douglas A. and Janet Vander Heide - Page 2

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               Respondent has also determined increased interest under                
          section 6621(c).1                                                           
               The main issues for decision are:  (1) Whether petitioners             
          were “protected against loss” within the meaning of section                 
          465(b)(4) with respect to their pro rata share of partnership               
          debt obligations arising from sale-leaseback transactions engaged           
          in by a partnership, and (2) whether additions to tax under                 
          sections 6653(a) and 6661(a) and increased interest under section           
          6621(c) are applicable.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  Petitioners both resided in California           
          when they filed the petition in the instant case.                           
               Petitioners timely filed joint Federal income tax returns              
          for the taxable years 1985 and 1986.  Petitioners deducted losses           
          and investment interest expenses (the claimed deductions)                   
          relating to Hambrose Leasing 1985-4 (the partnership) in the                
          following amounts:                                                          
                    Year           Loss       Investment Interest                     
                    1985      $27,985        $1,107                                   
                    1986      45,689         14,916                                   




               1  All section references are to the Internal Revenue Code             
          in effect for the years in issue.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  


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