Legal Opinion
Bergford v. Commissioner
Court of Appeals for the Ninth Circuit
Decided December 21, 1993No. Nos. 92-70241, 92-70242, 92-70443, 92-70445 and 92-70519PublishedCited by 5 opinions
1Opinion of the Court
RYMER, Circuit Judge:
This appeal requires us to decide whether the arrangement between owners of computer equipment and the manager of a sale-leaseback program to finance, purchase, lease, and remarket the equipment is a part*167nership subject to the unified audit and litigation provisions for partnership items under §§ 6221-6233 of the Internal Revenue Code. The five actions that are the subject of this consolidated appeal were initiated by taxpayers in the Tax Court'seeking redetermina-tions of the deficiencies in federal income tax and additions to tax determined by the Commissioner.1 The Tax…
2Cases cited13 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Luna v. CommissionerUnited States Tax Court · 1964
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
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3Cited by5 opinions
- City of New York v. A-1 Jewelry & Pawn, Inc.Court of Appeals for the Second Circuit · 2011
- Gerald W. Bergford v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Holdner v. Comm'rUnited States Tax Court · 2010
- Lattin v. CommissionerUnited States Tax Court · 1995
- Momot v. Comm'rUnited States Tax Court · 2006