Durkin v. Commissioner
United States Tax Court
D was a limited partner in B, and G was an indirect limited partner in S. PPC, a producer and distributor of major movies, sold all of its rights, except sequel rights, in six movies to FWC. FWC paid PPC cash and short-term recourse notes equal to 25 percent of the negative cost and long-term nonrecourse notes equal to 75 percent of the negative cost of each movie.
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D was a limited partner in B, and G was an indirect limited partner in S. PPC, a producer and distributor of major movies, sold all of its rights, except sequel rights, in six movies to FWC. FWC paid PPC cash and short-term recourse notes equal to 25 percent of the negative cost and long-term nonrecourse notes equal to 75 percent of the negative cost of each movie. In 1977, on the same day it purchased two of the six movies, FWC sold them to B. In 1978, on the same day it purchased the remaining four of the six movies, FWC sold them to S. B and S paid cash and short-term recourse notes in…
1Opinion of the Court
Thomas J. Durkin and Colette A. Durkin, Petitioners v. Commissioner of Internal Revenue, Respondent; Jerome A. Grossman and Sybil G. Grossman, Petitioners v. Commissioner of Internal Revenue, Respondent
Durkin v. Commissioner
Docket Nos. 18885-82, 25313-82, 22937-83, 4229-84, 17602-84, 17677-84, 27623-84
United States Tax Court
87 T.C. 1329; 1986 U.S. Tax Ct. LEXIS 7; 87 T.C. No. 79;
December 22, 1986, Filed
Decisions will be entered under Rule 155.
D was a limited partner in B, and G was an indirect limited partner in S. PPC, a producer and distributor of major movies, sold all of its rights,…
2Cases cited69 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
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