Saba Partnership, Brunswick Corporation, Tax Matters Partner - Page 25

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          petitioner cites does not amount to a nontax business purpose for           
          the partnerships.                                                           
          Conclusion                                                                  
               We hold that there is no meaningful distinction between the            
          partnerships in these cases and the partnership determined to be            
          a sham in ASA Investerings Pship. v. Commissioner, supra.  We               
          further hold that Saba and Otrabanda were not organized or                  
          operated for a nontax business purpose under the rationale of               
          Moline Properties v. Commissioner, supra.                                   
               To reflect the foregoing,                                              
                                             Decisions will be entered                
                                        under Rule 155.                               

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