Allison v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiffs are limited partners in a real estate partnership. Defendant adjusted plaintiffs’ 1983 and 1984 income tax returns as to partnership expenses and income. Defendant found that the terms of a partnership sale-leaseback were not consistent with economic realities. Defendant required plaintiffs to accrue rental income uniformly over the lease period and adjusted the allowable interest rate on the purchase note. (Stipulation of Facts ¶ 25, at 6.) Plaintiffs appealed to this court. The parties have submitted the case to the court based on stipulated facts, briefs and…