- 10 - not give effect to the allocation of profits and losses contained in the Partnership Agreement, * * *, (e) the risk that an audit of the Partnership’s income tax return may result in an audit of a Limited Partners’ own individual tax return * * *. * * * * * * * The income tax returns of the Partnership may be audited, and in turn, such audit may result in the audit of the returns of each Partner. In addition, the Commissioner of Internal Revenue has announced that the Service is engaged in a program of intensified audits of partnerships. Various deductions claimed by the Partnership on its returns of income could be disallowed in whole or in part on audit, which would result in an increase in the taxable income of the Partnership, and in turn, each Partner. If a tax deficiency is determined, the taxpayer is liable for interest (compounded on a daily basis) on such deficiency from the due date of the return. * * * * * * * BASED ON THE INVESTMENT OBJECTIVES OF THE PARTNERSHIP, THE GENERAL PARTNERS BELIEVE THAT THERE ARE SUBSTANTIAL GROUNDS FOR ARGUING THAT THE PARTNERSHIP IS NOT A “TAX SHELTER.” HOWEVER, NO ASSURANCE CAN BE GIVEN THAT THE IRS WILL NOT ATTEMPT TO CLASSIFY THE PARTNERSHIP AS A TAX SHELTER NOR WHETHER SUCH ATTEMPT WOULD BE SUCCESSFUL. * * * * * * * THE FOREGOING ANALYSIS CANNOT BE, AND IS NOT INTENDED AS, A SUBSTITUTE FOR CAREFUL TAX PLANNING, ACCORDINGLY, PARTNERS ARE URGED TO CONSULT THEIR TAX ADVISORS WITH RESPECT TO THEIR TAX SITUATION AND THE EFFECTS OF OWNING PARTNERSHIP UNITS. Tax Returns Petitioner and Mr. Bartak filed joint Federal income tax returns for 1980, 1981, 1982, 1983, 1984, 1985, and 1986. ForPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011