- 2 - 6651(a)(1)1 addition to tax of $10,812. After a concession,2 the issues for decision are: (1) Whether petitioners had any basis in the partnership interests which they sold during 2001 for $199,375, and (2) whether petitioners can exclude any part of the $199,375 proceeds from the sale of the partnership interests from taxable income in 2001. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time they filed the petition, petitioners resided in Broomfield, Colorado. All references to petitioner in the singular are to Joseph D. Doll. Petitioner organized Custom Design and Manufacturing (CDM) and Accelerated I/O (AIO), both Delaware C corporations. Petitioner also formed Colorcom Ltd. (Colorcom), a Colorado limited partnership. CDM is the general partner of Colorcom. Petitioner is the president of CDM and owns 80 percent of the stock of CDM. Colorcom owns 80 percent of AIO, and AIO owns 80 percent of Colorcom. CDM, Colorcom, and AIO are all working on 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Respondent conceded that no addition to tax pursuant to sec. 6651(a)(1) is due from petitioners for 2001.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011