Herschel H. and Roberta S. Hoopengarner - Page 4

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          B. and Victoria T. Hornbeak under California law.  The main                 
          purpose of the partnership was to acquire real property in                  
          Irvine, California, and to construct and rent a building on the             
          site.  Grant Hornbeak was the managing partner.  Petitioners and            
          the Hornbeaks each owned a 50-percent interest in the partnership           
          and shared net profits and net losses equally.  The agreement               
          stated:                                                                     
                    The Managing Partner shall provide quarterly                      
               financial statements of the partnership’s activities to                
               each partner.  In addition, the Managing Partner shall                 
               furnish each partner with a copy of the income tax                     
               return filed by the partnership * * *.                                 
               *      *      *      *      *       *      *                           
                    All books, records and accounts of the partnership                
               shall be open to inspection by all partners * * *.                     
               Petitioner brought an asset base to the partnership so that            
          the partnership could secure bank loans to construct the                    
          buildings.  The bank loans were secured with some of petitioner’s           
          personal assets.  Grant Hornbeak provided services for, and day-            
          to-day management of, the partnership in return for monetary                
          compensation.                                                               
               The only return filed for the partnership (on March 12,                
          1984) was for the taxable year ending September 30, 1982.                   
               On September 30, 1982, the partners dissolved the                      
          partnership.  The partnership was unsuccessful due to                       
          historically high interest rates of approximately 20 percent.               







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