CC&F Western Operations Limited Partnership, CC&F Investors, Inc., Tax Matters Partner - Page 2




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          Items Under Code Section 6226.  After concessions, the sole                 
          remaining issue is whether disclosures made in the 1990 Federal             
          income tax returns of Western and of partnerships in which                  
          Western owned interests were adequate to apprise respondent of              
          the nature and amount of omitted items and, thereby, to preclude            
          the application of the 6-year period of limitations under section           
          6229(c)(2).  This issue is before the Court on cross-motions for            
          summary judgment pursuant to Rule 121.  The record shows, and the           
          parties agree, that there is no genuine issue of material fact.             
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                     Background                                       
               Western is a Delaware limited partnership whose principal              
          place of business was Boston, Massachusetts.  Petitioner is a               
          corporation organized under Delaware law.                                   
               Western’s sole activity was selling, to a third-party buyer,           
          Western’s 84-percent partnership interests in CC&F Bellevue                 
          Office Investment Co. (Bellevue), CC&F Cabot Plaza II Investment            
          Co. (Cabot Plaza), CC&F Chatsworth Investment Co. (Chatsworth),             
          CC&F Diamond Bar Investment Co. (Diamond Bar), CC&F Issaquah I              
          Investment Co. (Issaquah), CC&F Mira Loma Investment Co. (Mira              
          Loma), and CC&F Topanga Investment Co. (Topanga); Western’s                 





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