4
determined adjustments to TWA’s 1996 partnership return. The
notice was issued to Charles William Wright CPA Accounting Corp.
(Wright S Corp.), as Tax Matters Partner of TWA. The FPAA
described the disputed adjustment to TWA’s partnership return as:
It has been determined that the following individuals
are the actual partners of the partnership: Donald E.
Trainer (with a profits interest of 50 percent), and
Charles W. Wright (with a profits interest of 50
percent). It has also been determined that the
following pass-thrus [sic] are not actual partners of
the partnership: Donald E. Trainer, CPA, A/C (also
known as Donald E. Trainer Accounting Corp.), and
Charles William Wright, CPA, A/C (also known as Charles
William Wright, CPA, Accounting Corp.).[4]
GTWP is a partnership with its principal place of business
in Charleston, West Virginia.5 GTWP also is in the business of
providing public accounting services to its clients. An FPAA,
dated April 14, 2000, determined an adjustment to GTWP’s 1996
partnership return. The FPAA was issued to Wright S Corp., as
the Tax Matters Partner of GTWP. The FPAA described the disputed
adjustment to GTWP’s partnership return as:
It has been determined that the following individuals
are the actual partners of the partnership: Donald E.
Trainer (with a profits interest of 23 percent),
Charles W. Wright (with a profits interest of 23
percent), and Victor Grigoraci (with a profits interest
of 54 percent). It has also been determined that the
following pass-thrus [sic] are not actual partners of
the partnership: Donald E. Trainer, CPA, A/C (also
4 Respondent also made an adjustment to TWA’s deductions,
but this adjustment is not in dispute.
5 The parties have agreed that GTWP and TWA were separate
partnerships in 1996.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011