Epic Associates 84-III, William C. Griffith, Jr. - Page 3

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                  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                    

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Last modified: May 25, 2011