Fife v. Commissioner
United States Tax Court
Petitioners were limited partners in a partnership formed to acquire and distribute a motion picture film. In 1973, the partnership purchased the American and Canadian rights to distribute the picture for $ 75,000 cash, a negotiable promissory note of $ 90,000, and a nonrecourse note of $ 1,335,000 payable only out of the proceeds derived from the distribution of the film. The picture had been exhibited extensively in Europe prior to the purchase by the partnership.
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Petitioners were limited partners in a partnership formed to acquire and distribute a motion picture film. In 1973, the partnership purchased the American and Canadian rights to distribute the picture for $ 75,000 cash, a negotiable promissory note of $ 90,000, and a nonrecourse note of $ 1,335,000 payable only out of the proceeds derived from the distribution of the film. The picture had been exhibited extensively in Europe prior to the purchase by the partnership. The partnership claimed an investment tax credit on the picture and elected to compute depreciation on the picture by use of the…
1Opinion of the Court
Martin D. Fife and Barbara J. Fife, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Fife v. Commissioner
Docket Nos. 3150-80, 3154-80, 3155-80, 25463-81, 25603-81, 20922-82
United States Tax Court
82 T.C. 1; 1984 U.S. Tax Ct. LEXIS 128; 82 T.C. No. 1;
January 4, 1984, Filed
Petitioners were limited partners in a partnership formed to acquire and distribute a motion picture film. In 1973, the partnership purchased the American and Canadian rights to distribute the picture for $ 75,000 cash, a negotiable promissory note of $ 90,000, and a nonrecourse note of $ 1,335,000 payable…
2Cases cited16 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Welch v. HenrySupreme Court of the United States · 1938
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