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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