- 8 - under chapter 7 on November 20, 1991. Petitioner’s bankruptcy case closed in August 1993. 6. GSD’s Final Partnership Return GSD reported that interest accrued on the Sunbelt loan from its initial return in 1984 until its final return for 1991. GSD reported assets, loan balances, and accrued interest on its 1988, 1989, 1990, and 1991 Forms 1065, U.S. Partnership Return of Income, as follows: End of year End of year Year Assets loan balance accrued interest 1987 $65,156,718 $77,978,575 $11,276,795 1988 1,474 27,742,833 2,523,458 1989 1 27,742,833 5,297,741 1990 1 27,742,833 8,072,024 1991 1 27,742,833 9,531,373 GSD accrued interest expense on the Sunbelt note of $1,459,349 for 1991 from January 1 to July 11, 1991. On July 15, 1992, GSD filed a Form 1065 for the period from January 1 to July 11, 1991, which it designated as its final return. Petitioner signed GSD’s return for 1991 in his capacity as general partner. GSD deducted interest expense of $1,459,349 on its 1991 return (GSD’s 1991 accrued interest deduction). The interest deduction created a $1,459,349 loss (the 1991 loss) because GSD reported no income. The Schedules K-1, Partner’s 1(...continued) bankruptcy * * * a successor General Partner is elected by a majority in interest, and not in numbers of the remaining Partners;.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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