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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in San Francisco, California, at the time that
he filed his petition.
The Synergistics, Lumenetics, and Data Flex Partnerships
Beginning in 1980 to the present, petitioner has been in the
record promotion business working for various record companies.
During the 1980s, he was employed by Joseph Isgro (Isgro).
While working for Isgro, petitioner was introduced to
Isgro’s tax attorney, DiRicco. Through DiRicco, petitioner
became involved in a number of partnerships.
In 1982 petitioner was a limited partner in Synergistics.
Synergistics recorded its Certificate of Limited Partnership on
October 13, 1983, in San Mateo County, California. An amendment
to the Certificate of Limited Partnership was recorded on
November 10, 1983. Petitioner and his wife at the time, Valerie
A. Tashjian (Mrs. Tashjian), made a $60,000 capital contribution
to Synergistics at the time that it was formed. The Certificate
of Limited Partnership lists petitioner as a limited partner and
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