Life Care Communities of America, Ltd., A Florida Limited Partnership, Robert W. McMichael, A Partner Other Than The Tax Matters Partner - Page 1

                                  T.C. Memo. 2004-5                                   


                               UNITED STATES TAX COURT                                


              LIFE CARE COMMUNITIES OF AMERICA, LTD., A FLORIDA LIMITED               
           PARTNERSHIP, ROBERT W. MCMICHAEL, A PARTNER OTHER THAN THE TAX             
                           MATTERS PARTNER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21683-94.             Filed January 5, 2004.                

               B. Gray Gibbs, for petitioner.                                         
               Francis Mucciolo, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By Notice of Final Partnership Administrative           
          Adjustment (FPAA) dated August 8, 1994, respondent determined               
          that the purchase and sale of partnership interests between                 
          partners Robert McMichael (petitioner), Hudson Fowler, and                  
          Raymond Smith were effective on June 30, 1990, rather than on               
          January 13, 1989, and the correct distributive shares of                    






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