- 9 - Dondi through June 20, 1991, the date Dondi’s interest was transferred to Mr. Manchester. The 1991 return further reflected that, after June 20, 1991, 100 percent of IHCL’s net income was allocated to THEI. Respondent challenged the allocation of 100 percent of IHCL’s net income to THEI; respondent determined that for the period after June 20, 1991, Mr. Manchester should be allocated a portion of IHCL’s net income. Specifically, respondent determined that Mr. Manchester’s distributive share of IHCL’s net income should be increased by $814,296 and that his share of tax preference items should be increased by $23,490. This reallocation of IHCL’s net income reflects the pre-June 20, 1991, allocation of income and losses to Dondi: 1 percent to THEI and 99 percent to Mr. Manchester, as Dondi’s successor. The FPAA stated that “the adjustments in the distributive shares are determined in accordance with the partners’ interest in the partnership as the partnership has not shown that the allocation per the return is an allowable allocation under the provisions of the Internal Revenue Code.” In Interhotel Co. I, we held that the allocation of 100 percent of IHCL’s net income for 1991 to THEI lacked substantial economic effect and was inconsistent with the partners’ interests in the partnership. Accordingly, we sustained respondent’s reallocation of the majority of that income to Mr. Manchester. OnPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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