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 ofPage: 1 2 3 4 5 6 7 8 Next
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