Harrell v. Commissioner
United States Tax Court
P is a general partner in a limited partnership with 10 or fewer partners. Under the terms of the partnership agreement, certain partnership items are to be distributed either in proportion to the partners' capital contributions, or in accordance with the partners' partnership interests.
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P is a general partner in a limited partnership with 10 or fewer partners. Under the terms of the partnership agreement, certain partnership items are to be distributed either in proportion to the partners' capital contributions, or in accordance with the partners' partnership interests. Pursuant to sec. 704(b), I.R.C. 1954, the partners' distributive shares of those partnership items not covered by the partnership agreement are determined in accordance with the partners' partnership interests. During the year in issue, no items other than those covered in the agreement were allocated to the…
1Opinion of the Court
Robert L. Harrell and Anne N. Harrell, Petitioners v. Commissioner of Internal Revenue, Respondent
Harrell v. Commissioner
Docket No. 15819-87
United States Tax Court
91 T.C. 242; 1988 U.S. Tax Ct. LEXIS 105; 91 T.C. No. 21;
August 17, 1988; As amended Auguest 23, 1988 August 17, 1988, Filed
P is a general partner in a limited partnership with 10 or fewer partners. Under the terms of the partnership agreement, certain partnership items are to be distributed either in proportion to the partners' capital contributions, or in accordance with the partners' partnership interests. Pursuant to sec.…
Also in this document: Dissent.
2Cases cited10 opinions
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Dellacroce v. CommissionerUnited States Tax Court · 1984
- Calcutt v. CommissionerUnited States Tax Court · 1988
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