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the Tax Court Rules of Practice and Procedure. Petitioners
resided in Los Angeles, California, when the petition was filed.
Peter M. Hoffman and Susan L. Hoffman (Mr. Hoffman and
Ms. Hoffman, respectively) filed a joint Federal income tax
return for 1990. Before filing that return, they requested from
respondent two extensions of time to file, both of which were
granted. Their 1990 Federal income tax return (the original
return) was received by respondent on September 10, 1991.
The original return reported that either Mr. or Ms. Hoffman
was a partner in the following partnerships: (1) Twelve Star
Partners, Ltd., (2) Thirteen Star Partners Limited, (3) Cabrillo
Palms Associates, (4) Desert Investments, (5) Joliet Television
Stations, L.P., and (6) Orbis Television Stations, L.P. The
original return reported that either Mr. or Ms. Hoffman held a
limited partner interest in the partnerships, except for Desert
Investments, in which the original return reported that one of
petitioners was a general partner. The original return reported
that neither petitioner “materially participated” in the
activities of any of these partnerships within the meaning of
section 469. The original return reported that petitioners also
were shareholders in an S corporation, Cinema Products Corp.
(Cinema), and that they did not “materially participate” in the
activity of Cinema.
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