John G. Goettee, Jr. and Marian Goettee - Page 2

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              CHABOT, Judge:  This matter is before us on petitioners’                
         amended motion under Rule 1611 for reconsideration of our opinion            
         reported as Goettee v. Commissioner, T.C. Memo. 2003-43,                     
         hereinafter sometimes referred to as Goettee I.  In Goettee I, we            
         made findings of fact, which we adopt for purposes of this                   
         supplemental opinion.  For clarity, however, we begin with a                 
         brief recital of the facts pertinent to this supplemental                    
                                  FINDINGS OF FACT                                    
              During September 1981, petitioners acquired a limited                   
         partnership interest in The Thompson Equipment Associates                    
         partnership, hereinafter sometimes referred to as TEA.                       
         Petitioners claimed flowthrough losses from TEA on their tax                 
         returns for 1981, 1982, and 1983.  Petitioners carried back                  
         “credits/losses” from 1981 to 1978 and 1979.                                 
              On October 15, 1986, respondent sent to petitioners a notice            
         of deficiency, in which respondent made adjustments on account of            

               1  Unless indicated otherwise, all Rule references are to              
          the Tax Court Rules of Practice and Procedure.                              
               Petitioners filed a motion for reconsideration on March 27,            
          2003.  On May 27, 2003, pursuant to the Court’s order, they filed           
          their amended motion for reconsideration.                                   

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