- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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