Legal Opinion
Gary R. Frink, Sherry R. Frink v. Commissioner of Internal Revenue, (Two Cases) Gary R. Frink, Sherry R. Frink v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided August 8, 1986No. 85-2226 to 85-2228PublishedCited by 8 opinions
1Opinion of the Court
BUTZNER, Senior Circuit Judge:
The Commissioner appeals the Tax Court’s judgment that a real estate partnership could deduct the losses of Argo Hotels, Inc., in 1975, 1976, and 1977, because Argo was the nontaxable agent of the partnership. The taxpayers, who were investors in the partnership, appeal the court’s judgment allocating 11% of the enterprise’s losses to Coastal Golf, Inc. 1 The taxpayers contend that some of these losses were incurred by Argo. Because the taxpayers failed to establish that Argo’s relationship with the partnership was not dependent on the partnership’s control of…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Benjamin Raphan and Myrna Raphan v. The United StatesCourt of Appeals for the Federal Circuit · 1985
7 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Commissioner v. BollingerSupreme Court of the United States · 1988
- Elrod v. CommissionerUnited States Tax Court · 1986
- George v. CommissionerCourt of Appeals for the Fifth Circuit · 1988
- George v. CommissionerCourt of Appeals for the Fifth Circuit · 1986
- Gary R. Frink, Sherry R. Frink v. Commissioner of Internal Revenue, (Two Cases). Gary R. Frink, Sherry R. Frink v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1988
3 more not listed; retrieve them via the Exa API.