DIEGO INVESTORS-IV v. COMMISSIONER

Docket Nos. 16947-87, 25289-87, 35488-87.

58 T.C.M. 753 (1989)

T.C. Memo. 1989-630

Diego Investors-IV, E.C. Smith, Tax Matters Partner, et al. v. Commissioner.

United States Tax Court.

Filed November 27, 1989.


Attorney(s) appearing for the Case

Mitchell B. Dubick, 701 B St., San Diego, Calif., Sherri A. Groveman, Patrick J. Felix III, 401 W. A St., San Diego, Calif., and Edward C. Smith, Jr., 4901 Morena Blvd., San Diego, Calif., for the petitioners. Steven New, Zuzana Colaprete, Jeffrey A. Hatfield, Boris Siegel, and William H. Quealy, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

These three consolidated test cases involve deductions and credits claimed by petitioners and, in some instances, additions to tax determined by respondent in connection with audio master tape leases.2 Respondent disallowed claimed deductions and credits with respect to 33 partnerships involved in these related ventures, and with respect to certain individual partners. Some...

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