- 3 -
Among the adjustments summarized above, respondent
disallowed all of the interest and depreciation claimed as
deductions by each partnership. The principal issues in
these cases are whether certain nonrecourse promissory
notes issued by each partnership to purchase real estate
constitute bona fide indebtedness and whether the activity
of each partnership is an "activity not engaged in for
profit", as that phrase is defined by section 183(c).
Unless stated otherwise, all section references in this
opinion are to the Internal Revenue Code as in effect
during the years in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts and the exhibits attached
thereto are incorporated herein by this reference.
EA 83-XII and EA 84-III are limited partnerships. At the
time the instant petitions were filed on their behalf, each
partnership was doing business in the State of Virginia,
and the tax matters partners of each partnership, William
C. Griffith, Jr., and Dottie M. Griffith, resided in
Atlanta, Georgia. Both limited partnerships reported
Page: 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