Long v. Commissioner
United States Tax Court
Petitioner filed a motion for reconsideration of findings and opinion. Held, petitioners failed to meet their burden of proof. Held, further, the timing of a partner's reimbursement to another partner for the payment of partnership liabilities is irrelevant for purposes of sec. 752(a), I.R.C. 1954, where the reimbursed partner at all times had complete dominion and control over the assets with which reimbursement was made.
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Petitioner filed a motion for reconsideration of findings and opinion. Held, petitioners failed to meet their burden of proof. Held, further, the timing of a partner's reimbursement to another partner for the payment of partnership liabilities is irrelevant for purposes of sec. 752(a), I.R.C. 1954, where the reimbursed partner at all times had complete dominion and control over the assets with which reimbursement was made. Held, further, petitioners were not prejudiced by our holding under sec. 752(a), I.R.C. 1954.
1Opinion of the Court
Marshall Long and Betty C. Long, Petitioners v. Commissioner of Internal Revenue, Respondent
Long v. Commissioner
Docket No. 9088-76
United States Tax Court
71 T.C. 724; 1979 U.S. Tax Ct. LEXIS 179;
February 5, 1979, Filed
Petitioner filed a motion for reconsideration of findings and opinion. Held, petitioners failed to meet their burden of proof. Held, further, the timing of a partner's reimbursement to another partner for the payment of partnership liabilities is irrelevant for purposes of sec. 752(a), I.R.C. 1954, where the reimbursed partner at all times had complete dominion and control over…
2Cases cited6 opinions
- Long v. CommissionerUnited States Tax Court · 1978
- Lightsey v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1933
- Selwyn Operating Corp. v. CommissionerUnited States Board of Tax Appeals · 1928
- Owen D. Austin and Lois C. Austin v. United StatesCourt of Appeals for the Tenth Circuit · 1972
- Long v. CommissionerUnited States Tax Court · 1979
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