229 Ct. Cl. 794 | Ct. Cl. | 1982
Taxes; income tax; allocation of partnership profits and losses; deduction of expenses concerning project under § 236 of the National Housing Act; setoff; summary judgment. — In this suit for refund of 1971 income taxes, the Internal Revenue Service (IRS) disallowed a claimed charitable deduction for 2 units of the 1970 homestake production program and asserted a deficiency. Plaintiff paid the tax deficiency plus interest, and brought this suit. In an amended answer, defendant raised 5 offsets. Four of the pleaded offsets have been dismissed; the 5th contests the validity of a 1971 deduction taken by plaintiff representing his distributive loss as a limited partner in Rosewood Manor Apartments (the partnership). The partnership constructed, and now owns and manages, a multi-family