Marica Chama - Page 2




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               After concessions by petitioner, this Court must decide                
          whether petitioner is liable for income tax on $61,983, her                 
          distributive share of partnership income.                                   
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Chicago, Illinois, at the time             
          she filed her petition.                                                     
               Petitioner held a 5-percent interest in Sheridan Lake View             
          Partnership (Partnership).  The Partnership was engaged in the              
          business of renting buildings.                                              
               On December 31, 1993, the Partnership entered into a                   
          transaction where it sold a parcel of real estate commonly known            
          as 5050 North Sheridan Road, Chicago, Illinois (Sheridan), to               
          Steven and Craig Strange (the Stranges), and purchased two                  
          parcels of real estate commonly known as 1101-03 West Pratt                 
          Avenue, Chicago, Illinois (Pratt), and 3134-40 West Montrose                
          Avenue, Chicago, Illinois (Montrose), from the Stranges.  The               
          sales price of the Sheridan property was $3,975,000, and the                
          purchase price of the Pratt and Montrose properties,                        
          collectively, was $1,075,000.  A substantial mortgage was assumed           
          by the Stranges.                                                            
               For the taxable year 1993, Gerard Mader prepared the                   
          Partnership’s tax return.  The parties stipulated that the                  
          Partnership return included a Form 8824, Like-Kind Exchanges, and           
          reported a gain in the amount of $1,239,660 from the sale of the            





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