- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: This is a partnership-level proceeding subject to the unified audit and litigation procedures of sections 6221 through 6231.2 In the 1970s, reacting to a global energy crisis, the Federal Government reached out to private industry to help develop alternative energy sources, including synthetic fuels. In response, five major energy companies, through their subsidiaries, formed a partnership, Great Plains Gasification Associates (the partnership), to develop, construct, own, and operate a project to produce natural gas from coal (the project). The partnership financed the project with about one-half billion dollars of the partners’ equity contributions and a $1.5 billion loan (the loan) from the Federal Financing Bank (FFB). The loan was secured by a mortgage on the partnership’s assets and guaranteed by the U.S. Department of Energy (DOE). The parent 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. The tax matters partner for Great Plains Gasification Associates (the partnership) is ANR Gasification Properties Co. (ANR). The tax matters partner for the partnership did not file a petition for readjustment of partnership items. Transco Coal Gas Co. (Transco), a partner of the partnership other than the tax matters partner, satisfies the requirements of sec. 6226(b) and (d) and timely filed the petition on behalf of the partnership and Transco.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011