LaVerne v. Commissioner
United States Tax Court
Petitioners and other individuals each invested approximately $ 8,000 in various limited partnerships. Under the financial structure of the limited partnerships and under the terms of the limited partnership agreements, the investors had no potential to realize a profit on their investments. Held, losses claimed by each investor, which were in excess of $ 90,000, are disallowed.
1Opinion of the Court
SWIFT, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:
R. George LaVeme
_Interest and additions to tax2_
Year Deficiency Sec. 6621(c) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1982 $7,904.20 * $395.20 ** $790.40
Curt K. Cowles
_Interest and additions to tax_
Year Deficiency Sec. 6621(c) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
1979 $7,685.50
1982 $8,802.00 * $440.10 ** $880.20
Gary M. and DeAnne Gustin
_Interest and additions to tax_
Sec. Sec. Sec. Sec. Sec. Year Deficiency 6621(c) 6651(a)(1) 6653(a)(1) 6653(a)(2) 6661
1979 $570.00 - - - - - -…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Pallottini v. CommissionerUnited States Tax Court · 1988
13 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Sacks v. CommissionerUnited States Tax Court · 1994
- Paschall v. CommissionerUnited States Tax Court · 2011
- Lincir v. CommissionerCourt of Appeals for the Ninth Circuit · 2002
- Esgar Corp. v. Comm'rUnited States Tax Court · 2012
57 more not listed; retrieve them via the Exa API.