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shows DiRicco as the general partner. DiRicco signed the
certificate on behalf of petitioner and the other limited
partners as “Attorney in Fact”. On his Form 1040, U.S.
Individual Income Tax Return, for 1982, petitioner deducted
$55,122 as a loss attributable to Synergistics.
In 1983 petitioner was a limited partner in Lumenetics.
Lumenetics recorded its Certificate of Limited Partnership on
January 12, 1984, in San Mateo County. The certificate lists
petitioner as a limited partner and shows Robert Steinjann
(Steinjann) as the general partner. The certificate shows that
petitioner and Mrs. Tashjian made a $35,000 cash capital
contribution with a $70,000 note and had a 3.0702-percent
interest in the partnership. There is no signature by, or on
behalf of, petitioner or Mrs. Tashjian in the certificate. On
his Form 1040 for 1983, petitioner deducted losses attributable
to Lumenetics. However, the amount of the deduction claimed is
unknown because neither party has a copy of the tax return that
was filed for that year. On his Form 1040 for 1984, petitioner
deducted $277 attributable to Lumenetics and $361 attributable to
Synergistics.
In 1984 petitioner was a limited partner in Data Flex. Data
Flex recorded its Certificate of Limited Partnership on July 3,
1984, in the office of the secretary of state of the State of
California. The certificate shows Steinjann as the general
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