Legal Opinion
Hga Cinema Trust, Burton W. Kanter, Trustee v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided December 27, 1991No. 90-2101PublishedCited by 8 opinions
1Opinion of the Court
BAUER, Chief Judge.
In this appeal, we must decide whether a partnership’s long-term promissory notes represent valid debt. The United States Tax Court held that these notes were not valid indebtedness. We affirm.
I
The pertinent facts of this case have been set forth ably by the United States Tax Court. See HGA Cinema Trust, Burton Kanter, Trustee v. Commissioner of Internal Revenue, 57 T.C.M. (CCH) 1066 (1989). Here, we need only recite those facts essential to our decision. Petitioner-appellant HGA Cinema Trust (“HGA”), whose trustee is tax attorney Burton W. Kanter, held a 5.56 percent…
2Cases cited7 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Thomas J. Durkin, Colette A. Durkin, Jerome A. Grossman and Sybil G. Grossman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- Louis H. Lewis v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- David Bruce McMahan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
- Donald J. Peracchi Judith E. Peracchi v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- IPO II v. Comm'rUnited States Tax Court · 2004
- Coastal Heart Med. Group, Inc. v. Comm'rUnited States Tax Court · 2015
- Donald J. Peracchi Judith E. Peracchi v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
3 more not listed; retrieve them via the Exa API.