- 2 - partnership income, loss, deductions, and credits were determined based on their ownership percentages in accordance with section 706.1 After concessions, the sole issue for decision is whether petitioner was divested of his ownership interest in Life Care Communities of America, Ltd., on January 12, 1989, or June 30, 1990. FINDINGS OF FACT In October 1981, petitioner, Hudson D. Fowler, Jr. (Fowler), and Raymond N. Smith (Smith) formed FMS Properties, Inc., a Florida corporation (FMS), which developed a life care retirement center (retirement center). FMS became the sole general partner of FMS Properties, Ltd., a limited partnership (partnership), formed in December 1981. In January 1982, the partnership’s name was changed from FMS Properties, Ltd. to Life Care Communities of America, Ltd. Other entities created by petitioner, Smith, and Fowler, included Bentley Village, Inc., a Florida not-for-profit corporation (Bentley Village), and Life Care Communities Management Corporation, a Florida business corporation (management company). In the aggregate, FMS, the partnership, Bentley Village and the management company, directly and indirectly, owned and operated the retirement center. Bentley 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect during the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011