- 13 - shall rest exclusively with the General Partners.” Furthermore, petitioners executed a power of attorney that provided that the attorney-in-fact shall have the “authority to act in * * * [their] name[s] and on * * * [their] behalf in the * * * filing of * * * [a]ny other instrument which may be required to be filed by the Partnership * * * or by any governmental agency * * *.” Morever, with respect to the date of the formation of the partnership, petitioners’ hands are not exactly clean: They admit that they backdated documents indicating that their interest in the partnership commenced in July 1982, and they claimed tax deductions and credits predicated on that representation at least in part. In these circumstances, in order to disregard the records of the partnership, we would require a much stronger showing than the innuendo based on innuendo that petitioners argue here. See Estate of Durkin v. Commissioner, 99 T.C. 561 (1992). An appropriate order denying petitioners’ Motion to Dismiss for Lack of Jurisdiction will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011