These parcels, known as Vapors Club and Stag Club, were purchased for a total consideration of $376,566.99. (hereinafter "Yemco"), which was a corporation whose sole shareholders were Yemelos and Cosmas.īy deeds both dated September 24, 1973, again acting on behalf of Casren, Yemelos purchased in his own name two additional strips of land adjoining the hotel site. issued a license or franchise to operate a Hilton Hotel for a period of 20 years to Yemco, Inc. for a license or franchise to operate a Hilton hotel, relative to which a fee of $20,000 was paid.On August 20, 1973, Hilton Inns, Inc. In December of 1972, Yemelos applied to Hilton Inns, Inc. In that same year, Casren undertook the project of developing the Biloxi Hilton Hotel, a commercial resort and convention-oriented hotel to be constructed in Biloxi, Mississippi.īy warranty deed dated November 6, 1972, acting on behalf of Casren, Yemelos acquired title in his own name to 7.5 acres of land located in Biloxi, Mississippi (hereinafter "hotel site"). Yemelos owned 80 percent of Casren, and Cosmas owned the remaining 20 percent. Yemelos (hereinafter "Yemelos") and his mother-in-law, Phopho Cosmas (hereinafter "Cosmas"), formed a partnership or joint venture known as Casren Development Company (hereinafter "Casren"). Sidney Frederick Lafayette, 1976 4/15/77 Austin, Boustany Louisiana 1976 4/15/77 Texasįrem F. Rayford Louisiana 1976 4/15/77 Texasįrem F. McCollister Baton Rouge, 1977 4/15/78 Austin, Carpenter Baton Rouge, 1977 4/15/78 Austin,Ĭharles A. Toups Louisiana 1976 4/15/77 Texasĭavid R. Ertan Louisiana 1976 4/15/77 TexasĬaroline Norton, Baton Rouge, 1976 4/15/77 Austin,Įxecutrix, Estate Louisiana 1977 4/15/78 Texas Tuncay Ertan Alexandria, 1975 4/15/76 Austin, Petitioners Residence Year Date filed center Petitioners, who resided in the following locations at the times they filed their petitions herein, filed their Federal income tax returns for the years in issue with the following Internal Revenue Service Centers: The stipulations of facts and exhibits attached thereto are incorporated herein by this reference. Some of the facts have been stipulated and are so found. and Coastal Golf, Inc., which held legal title thereto, or to the individual petitioners herein, as partners in commendam 7 in Biloxi Hotel Properties Partnership and (2) whether the allocations of losses provided for in the written agreement of such partnership, as amended, possessed substantial economic effect in 1977 as to the three petitioners who entered the partnership as partners in commendam on December 16, 1977. McCollister 26994-82 12/31/77 11,165.00Īfter concessions, the issues remaining for our decision are: (1) Whether losses generated by the construction and operation of the Biloxi Hilton Hotel project are attributable to two corporations, styled Argo Hotels, Inc. Toups 7720-83 12/31/77 39,265.00īy amended answers, respondent asserted additional deficiencies, resulting in the following increased deficiencies in three of the foregoing cases: 6 KORNER, Judge: Respondent determined deficiencies and additions to tax against petitioners in these cases as follows: 2
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