Transpac Drilling Venture v. United States

OPINION

MARGOLIS, Judge.

This tax case comes before the court on both plaintiffs motion for partial summary judgment and defendant’s cross motion for summary judgment concerning plaintiffs claim for readjustment of partnership items.

Transpac Drilling Venture 1983-2 (“Trans-pac 83-2”), one of approximately 72 Transpac partnerships, filed timely partnership level returns in 1983 and 1984. Transpac 83-2 was a Delaware limited partnership comprised of two general partners and approximately 35 limited partners. Transpac 83-2 reported substantial losses for both years. Subsequent to the filing of its…