Life Care Communities of America, Ltd., A Florida Limited Partnership, Robert W. McMichael, A Partner Other Than The Tax Matters Partner - Page 8

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          underlying economic arrangement of the partners.  Sec. 1.704-               
          1(b)(5), Example (4)(ii), Income Tax Regs.  Petitioner failed to            
          address whether or not the economic effect of the allocation was            
          substantial.  Consequently, we conclude that petitioner has                 
          failed to establish that the economic effect of the allocation              
          was not substantial.  Accordingly, we sustain respondent’s                  
               Contentions we have not addressed are irrelevant, moot, or             

                                                  Decision will be entered            
                                             under Rule 155.                          

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Last modified: May 25, 2011