Peter M. and Susan L. Hoffman - Page 3

          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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