- 3 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011