- 14 -
were Sunroad Asset, Walter and Marian Turner Family Trust, and
Walter Turner IRA. That return reported that it covered the
taxable year of Sunroad limited partnership starting with its
commencement of business on November 17, 1998, and ended on
September 30, 1999, the last day of its fiscal year. That return
reported the income and expense of the marina as the income and
expense of Sunroad limited partnership.
Collins and his wife filed their 1998 individual income tax
return jointly. They included with that return a Form 8082 with
respect to four items reported on HCMP’s 1998 partnership return.
Collins reported on the Form 8082 that he was reporting these
items inconsistently with HCMP’s treatment of them. First, HCMP
reported on its 1998 partnership return and on Collins’s 1998
Schedule K-1, Partner’s Share of Income, Credits, Deductions,
etc., that the partnership return was a “Final return” and that
the Schedule K-1 was a “Final K-1". Collins reported on the Form
8082 that his 1998 Schedule K-1 was not final in that his HCMP
interest was “involuntarily terminated” and he remained a partner
until the final outcome of the lawsuit. Second, HCMP reported on
its 1998 partnership return that it had no debt as of the end of
the reported period, and it reported on Collins’s accompanying
1998 Schedule K-1 that Collins’s share of HCMP’s qualified
nonrecourse financing at that time was zero. Collins reported on
the Form 8082 that his share of HCMP’s qualified nonrecourse
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011