2925 BRIARPARK, LTD. v. COMMISSIONER

Docket No. 22320-94.

73 T.C.M. 3218 (1997)

T.C. Memo. 1997-298

2925 Briarpark, Ltd., James C. Motley, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed June 30, 1997.


Attorney(s) appearing for the Case

Alan L. Tinsley, Madisonville, Tex., and Charles B. Koerth, for the petitioner. Dennis M. Kelly, for the respondent.


MEMORANDUM OPINION

HAMBLEN, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) to 2925 Briarpark, Ltd. (Briarpark), and determined adjustments in Briarpark's ordinary income, gains derived from dealings in property, and the partners' capital accounts for 1989.1 After concessions, the issue for decision is whether the income realized from the discharge of nonrecourse loans should be treated...

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