Great Plains Gasification Associates, A Partnership, Transco Coal Gas Company, A Partner Other Than The Tax Matters Partner - Page 2

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                       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.                                                    

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Last modified: May 25, 2011