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purchase of an aircraft is allocable to Indeck Power Overseas
Ltd. (Indeck Overseas).
Background
The parties submitted this case fully stipulated pursuant to
Rule 122.2 The stipulation of facts and the attached exhibits
are incorporated herein by this reference.
IPO II is a limited liability company organized in 1996
under the Illinois Limited Liability Company Act. At the time
the petition was filed, IPO II’s principal place of business was
Wheeling, Illinois.
IPO II was treated as a partnership for Federal income tax
purposes for the years in issue. The members of IPO II are Mr.
Forsythe and Indeck Overseas. Indeck Overseas is an S
corporation in which Mr. Forsythe owned 100 percent of the
outstanding shares during the years in issue. The members’
interests in the profits and losses of IPO II were allocated
during the years in issue, and are currently allocated, as
follows: Indeck Overseas, 99 units; Mr. Forsythe, 1 unit.
IPO II’s operating agreement (operating agreement) provides
the following, in relevant part:
2 All Rule references are to the Tax Court Rules of
Practice and Procedure, and all section references are to the
Internal Revenue Code relevant to the years in issue. Amounts
are rounded to the nearest dollar.
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Last modified: May 25, 2011