122 T.C. No. 17 UNITED STATES TAX COURT IPO II, A PARTNERSHIP, GERALD R. FORSYTHE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14500-02. Filed April 23, 2004. IPO II, an LLC but treated as a partnership for Federal income tax purposes, is owned by IO, an S corporation, and F, an individual. F owns 100 percent of the outstanding stock in IO, 70 percent of the outstanding stock of IE, an S corporation, and 63 percent of the outstanding stock of IP, a C corporation. F’s daughters own the remaining 30 percent of the outstanding stock of IE. IPO II purchased an aircraft, and the loan was guaranteed by F, IE, and IP, but not IO. R determined that the liability incurred in the purchase of the aircraft was recourse and fully allocable to F. P argues that part of the liability should be allocated to IO because it is related to IE, a guarantor of the loan.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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