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GEMINI TWIN FUND III v. COMMISSIONER

Docket No. 6764-88.

62 T.C.M. 104 (1991)

T.C. Memo. 1991-315

Gemini Twin Fund III, William H. Breck, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed July 9, 1991.

Attorney(s) appearing for the Case

William H. Breck, pro se. Robert P. Crowther, for the respondent.

Memorandum Opinion

COHEN, Judge:

In a Notice of Final Partnership Administrative Adjustment (FPAA), respondent determined that the distributive share of the partnership loss of Gemini Twin Fund III (Gemini) as to the limited partners was limited to their cash invested and did not include promissory notes payable to Gemini. Unless othervise indicated, all section references are to the Internal Revenue Code as amended and in effect for the year in issue.<...

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