IPO II, A Partnership, Gerald R. Forsythe, Tax Matters Partner - Page 1

                                   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

Last modified: May 25, 2011