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During 1985, Ridge was a partner in two multiple tier
partnerships: (1) Pacific Real Estate Investors Partnership
(hereinafter sometimes referred to as Pacific) and (2) Carlyle
Real Estate Limited Partnership-VI (hereinafter sometimes
referred to as Carlyle).
Pacific was a partner in at least one other partnership.
Pacific’s 1985 information return shows an ordinary loss of
$7,705 from another partnership, identified by name and employer
identification number. The record does not include information
as to the amount of the gross income stated on this 2d-tier
partnership’s 1985 information return.
Carlyle was a partner in several other partnerships.
Carlyle’s 1985 information return shows ordinary income of
$674,791.81 from four other partnerships, each identified by name
and employer identification number. The record does not include
information as to the amounts of Carlyle’s shares of the gross
incomes stated on these 2d-tier partnerships’ 1985 information
returns.
On one of the schedules attached to their 1985 tax return,
the Harlans show their gross income as $1,216,099. This schedule
is for purposes of Form 1116, part I, line 2.d.(v), and is an
element of the formula used in the computation of their foreign
tax credit. Nevertheless, the parties have stipulated that the
gross income for purposes of section 6501(e) that is “reflected
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Last modified: May 25, 2011