Avers v. Commissioner
United States Tax Court
Ps, individual investors, each invested in 1981 as partners in separate partnerships which were formed to exploit master sound recordings leased K as part of a program promoted by K. During settlement negotiations, respondent refused to offer Ps a deduction for 100 percent of their out-of-pocket expenses in relation to their 1981 investment in the K program, an offer which respondent previously extended to all 1979 and 1980 investors in the K program and extended to various…
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Ps, individual investors, each invested in 1981 as partners in separate partnerships which were formed to exploit master sound recordings leased K as part of a program promoted by K. During settlement negotiations, respondent refused to offer Ps a deduction for 100 percent of their out-of-pocket expenses in relation to their 1981 investment in the K program, an offer which respondent previously extended to all 1979 and 1980 investors in the K program and extended to various other 1981 investors at the administrative stage. Held, the partnerships were "generic tax shelters" whose activities…
1Opinion of the Court
RONALD H. AND DOROTHY A. AVERS, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Avers v. Commissioner
Docket Nos. 12639-86; 12640-86; 12641-86; 12642-86; 12643-86; 26926-86.
United States Tax Court
T.C. Memo 1988-176; 1988 Tax Ct. Memo LEXIS 204; 55 T.C.M. (CCH) 678; T.C.M. (RIA) 88176;
April 26, 1988.
Ps, individual investors, each invested in 1981 as partners in separate partnerships which were formed to exploit master sound recordings leased K as part of a program promoted by K. During settlement negotiations, respondent refused to offer Ps a deduction for 100 percent of…
2Cases cited66 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Oyler v. BolesSupreme Court of the United States · 1962
- United States Ex Rel. Accardi v. ShaughnessySupreme Court of the United States · 1954
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
61 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Bunce v. United StatesUnited States Court of Federal Claims · 1993