- 2 -
SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION
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
opinion.
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011