Patty K. Copeland, a.k.a. Patty K. White - Page 7




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          seeking a deduction only for their out-of-pocket cash invested in           
          the partnerships.                                                           
               The Garfield and Cardinal limited partnerships did not                 
          constitute mere passive coowners of property.  These limited                
          partnerships entered into transactions, formed joint ventures,              
          operated gas wells, and engaged in various other activities.                
          They carried on a financial operation or venture.  They are to be           
          treated as partnerships under section 76l(a) even though the                
          underlying activities of the partnerships lacked a profit                   
          objective under section 183.  The Garfield and Cardinal limited             
          partnerships each had the formal indicia of partnership status              
          and conducted themselves generally as partnerships.  They are to            
          be treated as partnerships.                                                 
               The issue herein under section 183 as to profit objective is           
          to be analyzed at the partnership level.  The parties’                      
          stipulation that activities and transactions of the Garfield and            
          Cardinal limited partnerships were not entered into with a profit           
          objective does not affect the status of the partnerships as                 
          partnerships for Federal income tax purposes.                               

          Section 6621(c) Increased Interest                                          
               With regard to increased interest under section 6621(c),               
          among other arguments, petitioners contend that the temporary               
          regulations under section 6621 that extended increased interest             
          to transactions lacking a profit objective are invalid and that             





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