- 7 -
transactions of the partnerships were tax-motivated and did not
constitute legitimate for-profit business transactions.
Petitioners agree to be bound by Krause v. Commissioner, supra,
with respect to the activities of White Rim. Therefore, we
conclude that the activities and transactions of the White Rim
partnership, like those of Technology 1980, were not legitimate
profit-oriented business dealings and lacked economic substance.
Because the activities and transactions of the White Rim
partnership lack economic substance, petitioners are not entitled
to a loss deduction under section 165(c)(2) for their cash
investment in the White Rim partnership, notwithstanding their
individual profit objective in investing in the partnership.
To reflect the foregoing,
An appropriate order will be
issued.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011