Taube v. Commissioner
United States Tax Court
Petitioner husbands were limited partners in A, which in 1979 acquired "all right, title and interest" in two nursing training films from AF, in exchange for cash and a recourse promissory note due in 1987. Each limited partner executed an assumption agreement by which he became personally liable to AF on that part of the principal balance of the recourse note, proportionate to his share in the partnership, still due and owing in 1987. Held, A purchased an ownership interest…
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Petitioner husbands were limited partners in A, which in 1979 acquired "all right, title and interest" in two nursing training films from AF, in exchange for cash and a recourse promissory note due in 1987. Each limited partner executed an assumption agreement by which he became personally liable to AF on that part of the principal balance of the recourse note, proportionate to his share in the partnership, still due and owing in 1987. Held, A purchased an ownership interest in the films. Held, further, the transaction was entered into with a bona fide objective to make a profit. Held,…
1Opinion of the Court
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes for the year 1979:
Docket No. Deficiency
13922-83.$7,654
13992-83 . 23,313
After concessions, we must determine whether Andrama I Partners, Ltd., a limited partnership, was entitled to various deductions and an investment tax credit with respect to its purchase and distribution of nursing training films and, in turn, whether petitioners were entitled to their distributive shares of such deductions and credit.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. This reference…
2Cases cited38 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Dreicer v. CommissionerUnited States Tax Court · 1982
- United States v. CartwrightSupreme Court of the United States · 1973
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3Cited by84 opinions
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