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KINGSTOWNE L.P. v. COMMISSIONER

Docket No. 1936-93.

68 T.C.M. 1497 (1994)

T.C. Memo. 1994-630

Kingstowne L.P., Warren E. and Martha D. Halle, Partners Other Than The Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed December 21, 1994.

Attorney(s) appearing for the Case

Patrick G. Dooher, 1776 "K" St., N.W., Washington, D.C., for the petitioners. David L. Click and Richard D. Fultz, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) on August 28, 1992, determining adjustments to the 1985 partnership return of Kingstowne L.P.

The sole issue for decision is whether the partnership may report as interest, pursuant to section 163, $900,000 that it paid to the sellers of Greendale Development Co. (Greendale) to extend the settlement date for the partnership...

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