Aron B. Katz and Phyllis A. Katz - Page 3




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               During 1990, petitioner Aron B. Katz (Mr. Katz) held limited           
          partnership interests in a number of partnerships.  Each of the             
          partnerships used the calendar year for tax reporting purposes,             
          as did Mr. Katz.                                                            
               On July 5, 1990, Mr. Katz commenced a bankruptcy proceeding            
          in the U.S. Bankruptcy Court for the Southern District of New               
          York by filing a petition for relief under chapter 7 of the U.S.            
          Bankruptcy Code.  Mr. Katz did not make an election under section           
          1398(d)(2) to bifurcate his 1990 taxable year into two short                
          taxable years on account of his bankruptcy filing.  Accordingly,            
          Mr. Katz’ individual income tax return for 1990, on which he                
          claimed the status of a married person filing separately, covered           
          the entire calendar year.                                                   
               On account of Mr. Katz’ bankruptcy proceeding, some of the             
          partnerships undertook an interim closing of the books with                 
          respect to Mr. Katz’ partnership interest in determining his                
          distributive share of partnership tax items for 1990.  In doing             
          so, each of these partnerships subdivided the distributive share            
          determined in respect of Mr. Katz’ interest for the entire 1990             
          partnership taxable year (the 1990 calendar year distributive               
          share) into two categories:  The first consisted of those items             
          attributable to the period prior to July 5, 1990 (the prepetition           
          items), and the second consisted of those items attributable to             
          the remainder of the 1990 calendar year (the postpetition items).           






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