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account to go negative. The determinations in the partnership-
level TEFRA proceeding--to which we are bound to give effect--
have resulted in the recapture of those tax benefits and also
take into account the current economic benefit petitioner
realized as a partner in 1992 from the discharge of his share of
the remaining liability to the firm’s creditors. What goes
around comes around.
To reflect the foregoing,
Decision will be entered
in accordance with respondent’s
computations.
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Last modified: May 25, 2011