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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