T.C. Memo. 2002-276
UNITED STATES TAX COURT
FRGC INVESTMENT, LLC, JAMES P. MEHEN, TAX MATTERS PARTNER,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5443-01. Filed October 31, 2002.
Stephen E. Silver and Jason M. Silver, for petitioner.
Michael L. Boman and James E. Cannon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent sent a Notice of Final Partnership
Administrative Adjustment (FPAA) for 1997 and 1998 to FRGC
Investment, LLC (FRGC). James P. Mehen (petitioner), the
designated tax matters partner for FRGC, filed a timely petition
for readjustment with the Court. The issues for decision are:
(1) Whether FRGC’s expenses in 1997 are deductible as an
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