- 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