- 89 -
investment expenses of $908,960 and $909,831, respectively,
and the investment interest income of $90 and $1,262,
respectively. In support of these other adjustments, the
notices of FPAA issued to EA 83-XII state that "it has not
been established that there was an actual investment
associated with the acquisition of the property or that
there was genuine indebtedness on the property." In
further support of these other adjustments, the notices
state that the activity of EA 83-XII for 1983, 1984, 1985,
and 1986 "was not engaged in for profit."
Notices of FPAA Issued to EA 84-III
In the notices of FPAA issued to EA 84-III for 1983,
1984, and 1985, respondent adjusted the ordinary income
reported by the partnership as shown below in the second
column for each year:
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