Sparks v. Commissioner
United States Tax Court
Ps are partners in the Project Omega Limited Partnership (the partnership). A portion of the deficiency determined by R for Ps' taxable year 1982 arises from adjustments to partnership items of the partnership.
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Ps are partners in the Project Omega Limited Partnership (the partnership). A portion of the deficiency determined by R for Ps' taxable year 1982 arises from adjustments to partnership items of the partnership. The offering memorandum, the limited partnership agreement of the partnership, and other documents state that the partnership will be formed upon termination of the offering which occurred in December of 1982. As of Sept. 3, 1982, the partnership's escrow account held $ 24,000, representing 4 units of participation (of a total of 80 units to be sold), and the general partner had begun…
1Opinion of the Court
Frank D. Sparks and Emily J. Sparks, Petitioners v. Commissioner of Internal Revenue, Respondent
Sparks v. Commissioner
Docket No. 42022-85
United States Tax Court
87 T.C. 1279; 1986 U.S. Tax Ct. LEXIS 9; 87 T.C. No. 74;
December 8, 1986, Filed
Ps are partners in the Project Omega Limited Partnership (the partnership). A portion of the deficiency determined by R for Ps' taxable year 1982 arises from adjustments to partnership items of the partnership. The offering memorandum, the limited partnership agreement of the partnership, and other documents state that the partnership will be formed upon…
2Cases cited9 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Sparks v. CommissionerUnited States Tax Court · 1986
- Dwinell's Central Neon v. Cosmopolitan Chinook HotelCourt of Appeals of Washington · 1978
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