- 63 - the recipients, Mr. Winn and Mr. Curtis, pursuant to sections 731(a)(1) and 752. Therefore, we shall grant the motion.31 An order granting participating partner’s motion for partial summary judgment will be issued. 31 If all of respondent’s arguments in this case, docket No. 22023-05, and the Court of Federal Claims actions instituted by CLPP and MP were to be sustained, the overall effect would be to tax the gain realized on the sale of the Manchester property three times: First, in 2000, to Mr. Winn and Mr. Curtis on the liquidating distribution, a second time, in 2001, to Countryside on the sale of the Manchester property, and a third time, in 2003, on AIG’s redemption of the AIG notes from MP. We suspect that respondent’s position in these actions is intended to completely offset what respondent considers to be participating partner’s and petitioner’s goal of deferring indefinitely any tax on that gain and to avoid any possibility of being whipsawed. In addressing the motion, we decide only that the gain is not recognized to Mr. Winn and Mr. Curtis in 2000 upon their receipt of a 99-percent limited partnership interest in CLPP or, alternatively, upon their deemed receipt of the AIG notes.Page: Previous 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 NextLast modified: March 27, 2008