Pritchett v. Commissioner
United States Tax Court
Petitioners were limited partners in similar oil and gas drilling partnerships. They made initial cash contributions to their respective partnerships and agreed to make future additional cash contributions if called upon to do so by the general partners in order to satisfy 15 year recourse notes executed by the partnerships in favor of a drilling company.
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Petitioners were limited partners in similar oil and gas drilling partnerships. They made initial cash contributions to their respective partnerships and agreed to make future additional cash contributions if called upon to do so by the general partners in order to satisfy 15 year recourse notes executed by the partnerships in favor of a drilling company. During each year at issue, each partnership incurred a loss, and each petitioner claimed his distributive share of partnership loss in an amount which included both his actual cash contribution to the partnership, as well as his…
1Opinion of the Court
Jerry E. Pritchett and Patricia D. Pritchett, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Pritchett v. Commissioner
Docket Nos. 14586-81, 18127-81, 18128-81, 18477-81, 27413-82
United States Tax Court
85 T.C. 580; 1985 U.S. Tax Ct. LEXIS 27; 85 T.C. No. 35; 87 Oil & Gas Rep. 195;
October 24, 1985, Filed
Decisions will be entered for the respondent.
Petitioners were limited partners in similar oil and gas drilling partnerships. They made initial cash contributions to their respective partnerships and agreed to make future additional cash contributions if called upon to do so…
Also in this document: Concurrence; Dissent · Whitaker; Dissent · Hamblen; Dissent · Cohen.
2Cases cited14 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Helvering v. StuartSupreme Court of the United States · 1942
- Lucas v. HammCalifornia Supreme Court · 1961
- Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
- Gilbert Financial Corp v. Steelform Contracting Co.California Court of Appeal · 1978
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