Law v. Commissioner
United States Tax Court
P was a limited partner in D, a partnership formed in 1978. In 1977 and 1978, N produced a major motion picture film. Under a distribution agreement, N sold all rights (excepting network television rights) to such film in the United States and Canada to AIP, a distribution company, in return for a production advance and all proceeds of the film's distribution remaining after AIP recouped its advance and its distribution fee and expenses.
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P was a limited partner in D, a partnership formed in 1978. In 1977 and 1978, N produced a major motion picture film. Under a distribution agreement, N sold all rights (excepting network television rights) to such film in the United States and Canada to AIP, a distribution company, in return for a production advance and all proceeds of the film's distribution remaining after AIP recouped its advance and its distribution fee and expenses. In 1978, through a series of transactions involving two "strawman" entities, D purportedly purchased from AIP all rights (excepting network television) to…
1Opinion of the Court
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income taxes of $7,962 for 1978 and $17,146 for 1979. The issues for decision are: (1) Whether William J. Law, as a limited partner in a partnership purportedly engaged in the purchase and distribution of a motion picture, is entitled to deductions for a distributive share of losses reported by the partnership and, if so, in what amounts; and (2) whether the petitioner is entitled to an investment tax credit.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners,…
2Cases cited32 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dreicer v. CommissionerUnited States Tax Court · 1982
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3Cited by44 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Gefen v. CommissionerUnited States Tax Court · 1986
- Leahy v. CommissionerUnited States Tax Court · 1986
- Larsen v. CommissionerUnited States Tax Court · 1987
- Ronnen v. CommissionerUnited States Tax Court · 1988
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