Johnsen v. Commissioner
United States Tax Court
L, a limited partnership, was formed in April 1976 to develop an apartment project. P became a limited partner in July 1976. In our opinion in Johnsen v. Commissioner, 83 T.C. 103 (1984), we held that P was entitled to deduct his distributive share of a construction loan commitment fee, a management and guarantee fee, and a portion of a permanent loan commitment fee incurred by L during 1976. We also held that, under sec. 706(c)(2)(B), I.R.C. 1954, P must adjust his…
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L, a limited partnership, was formed in April 1976 to develop an apartment project. P became a limited partner in July 1976. In our opinion in Johnsen v. Commissioner, 83 T.C. 103 (1984), we held that P was entitled to deduct his distributive share of a construction loan commitment fee, a management and guarantee fee, and a portion of a permanent loan commitment fee incurred by L during 1976. We also held that, under sec. 706(c)(2)(B), I.R.C. 1954, P must adjust his distributive share of such items to reflect the fact that he was not a member of L during its entire 1976 taxable year. However,…
1Opinion of the Court
SUPPLEMENTAL OPINION
Simpson, Judge:
On July 24, 1984, this Court filed its opinion (83 T.C. 103) determining the issues in this case and withheld entry of its decision for the purpose of permitting the parties to submit computations under Rule 155, Tax Court Rules of Practice and Procedure.1 The parties submitted conflicting computations. On November 21, 1984, we entered our decision, adopting the Commissioner’s computation that there was a deficiency of $2,698 in the income tax due from the petitioners for the taxable year 1976. The petitioners, John K. and Frances Johnsen, have moved to…
2Cases cited8 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Johnsen v. CommissionerUnited States Tax Court · 1984
- Moore v. CommissionerUnited States Tax Court · 1978
- Roccaforte v. CommissionerUnited States Tax Court · 1981
- Joseph A. Roccaforte, Jr. And Sandra F. Roccaforte, Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1983
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Finoli v. CommissionerUnited States Tax Court · 1986
- Cottle v. CommissionerUnited States Tax Court · 1987
- Mary K.S. Ogden v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Ogden v. CommissionerUnited States Tax Court · 1985
- Weiner v. United StatesDistrict Court, S.D. Texas · 2002
4 more not listed; retrieve them via the Exa API.