- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT The parties have stipulated many of the facts, which we incorporate by this reference. When petitioner filed her petition, she resided in Fruitport, Michigan. A. Formation of the Lappo Family Limited Partnership On October 20, 1995, petitioner and her daughter, Clarajane Middlecamp (Clarajane), formed, pursuant to Georgia law, the Lappo Family Limited Partnership (the partnership). On April 19, 1996, petitioner and Clarajane conveyed to it a portfolio of marketable securities (principally municipal bonds) and certain parcels of Michigan real estate that were subject to a long-term lease.1 After these initial capital contributions, petitioner’s and Clarajane’s respective partnership interests were as follows: General Limited Partnership Partnership Partner Interest Interest Total Petitioner 1.0 98.7 99.7 Clarajane .2 .1 .3 Total 1.2 98.8 100.0 1 The real estate parcels, in Fruitport, Mich., and South Haven, Mich., were sites of two retail lumberyards formerly owned and operated by the Lappo family. In June 1995, Wickes Lumber Co. purchased all the lumberyard assets other than the real estate and entered into a 15-year lease for the real estate.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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