- 5 - which had economic substance and constituted a trade or business for all purposes of the Internal Revenue laws, and (3) the partnership engaged in the trade or business of farming primarily for the purpose of earning profits. Additional History of the Case On July 30, 1990, respondent moved to extend the time within which to move or answer the petition from July 30, 1990, to August 27, 1990. We granted that motion on August 2, 1990. On August 13, 1990, respondent moved to stay the proceedings prior to answer for a period of 1 year (the motion to stay). In support of the motion to stay, respondent claimed that petitioner and certain others were under criminal investigation for their activities in connection with the partnership and other partnerships sponsored by Amcor Capital, Inc., formerly American Agri-Corp. (without distinction, AMCOR). Although petitioner was not, then, a participating partner, see Rule 247(b), and respondent claimed that none of the participating partners were under criminal investigation for their activities in connection with any AMCOR-related partnership, respondent believed that a stay was required to avoid conflicts and difficulties arising from the ongoing criminal investigation of petitioner and certain others. The petitioning partners objected to the motion to stay, arguing, among other things, that not only were none of the participating partners under any related criminal investigationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011