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Timothy G. Buck and Michael D. Culy, for petitioner in
docket No. 9553-94.
Michael A. MacDonald, for petitioner in docket No. 384-95.
Catherine J. Caballero and Paul Robeck, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Stanley J. Goldberg, pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent issued a notice
of final partnership administrative adjustment (FPAA) to each
partnership involved in these consolidated cases determining the
adjustments in the amounts and for the taxable years as set forth
in Appendix A hereto.3
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
3The years in issue for River City Ranches #4 are 1987,
1988, its year ended Sept. 30, 1989, year ended Sept. 30, 1990,
and year ended Sept. 30, 1991. Respondent granted River City
Ranches #4 permission to change to a taxable year ended Sept. 30,
beginning with its year ended Sept. 30, 1989. The years in issue
for River City Ranches #6 are 1987, 1988, its year ended Sept.
(continued...)
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