Legal Opinion

Diamond v. Commissioner

United States Tax Court

Decided February 23, 1989No. Docket No. 39473-86Published

Petitioner was a limited partner in Robotics which was a limited partner in the project partnership, an Israeli limited partnership. The project partnership's general partner was Elco, a publicly held Israeli corporation. The project partnership was formed to conduct research and development work with respect to an arc welder with an optical seam follower.

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Petitioner was a limited partner in Robotics which was a limited partner in the project partnership, an Israeli limited partnership. The project partnership's general partner was Elco, a publicly held Israeli corporation. The project partnership was formed to conduct research and development work with respect to an arc welder with an optical seam follower. The project partnership agreement gave Elco the right to manufacture, produce, and/or market the welder as exclusive and irrevocable licensee. Held, expenditures of the project partnership were not in connection with any trade or business,…

1Opinion of the Court

Louis H. and Madelene Diamond, Petitioners v. Commissioner of Internal Revenue, Respondent

Diamond v. Commissioner

Docket No. 39473-86

United States Tax Court

92 T.C. 423; 1989 U.S. Tax Ct. LEXIS 30; 92 T.C. No. 25;

February 23, 1989; As amended March 1, 1989 February 23, 1989, Filed

Decision will be entered under Rule 155.

Petitioner was a limited partner in Robotics which was a limited partner in the project partnership, an Israeli limited partnership. The project partnership's general partner was Elco, a publicly held Israeli corporation. The project partnership was formed to conduct research and…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Gregory v. HelveringSupreme Court of the United States · 1935
  4. Rose v. CommissionerUnited States Tax Court · 1987
  5. Surloff v. CommissionerUnited States Tax Court · 1983

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