T.C. Memo. 2003-31
UNITED STATES TAX COURT
SABA PARTNERSHIP, BRUNSWICK CORPORATION,
TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
OTRABANDA INVESTERINGS PARTNERSHIP, BRUNSWICK CORPORATION,
TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1470-97, 1471-97. Filed February 11, 2003.
During 1990 and 1991, B, a domestic corporation,
realized substantial capital gains from the sale of a
number of its business units.
In 1990, B joined with a foreign bank (ABN)
purportedly to form two general partnerships, S and O.
The partnerships engaged in financial transactions that
were intended to satisfy the requirements of a
contingent installment sale under I.R.C. sec. 453.
Relying on the ratable basis recovery rules under sec.
15A.453-1(c), Temporary Income Tax Regs., 46 Fed. Reg.
*This opinion supplements our previously filed Memorandum
Opinion in Saba Pship. v. Commissioner, T.C. Memo. 1999-359,
vacated and remanded 273 F.3d 1135 (D.C. Cir. 2001).
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