Legal Opinion

IPO II v. Comm'r

United States Tax Court

Decided April 23, 2004No. 14500-02Published

IPO II, an LLC but treated as a partnership for Federal income tax purposes, is owned by IO, an S corporation, and F, an individual. F owns 100 percent of the outstanding stock in IO, 70 percent of the outstanding stock of IE, an S corporation, and 63 percent of the outstanding stock of IP, a C corporation. F's daughters own the remaining 30 percent of the outstanding stock of IE. IPO II purchased an aircraft, and the loan was guaranteed by F, IE, and IP, but not IO.

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IPO II, an LLC but treated as a partnership for Federal income tax purposes, is owned by IO, an S corporation, and F, an individual. F owns 100 percent of the outstanding stock in IO, 70 percent of the outstanding stock of IE, an S corporation, and 63 percent of the outstanding stock of IP, a C corporation. F's daughters own the remaining 30 percent of the outstanding stock of IE. IPO II purchased an aircraft, and the loan was guaranteed by F, IE, and IP, but not IO. R determined that the liability incurred in the purchase of the aircraft was recourse and fully allocable to F. P argues that…

1Opinion of the Court

IPO II, A PARTNERSHIP, GERALD R. FORSYTHE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

IPO II v. Comm'r

No. 14500-02

United States Tax Court

122 T.C. 295; 2004 U.S. Tax Ct. LEXIS 17; 122 T.C. No. 17;

April 23, 2004, Filed

Recourse liability was fully allocable to Mr. Forsythe.

IPO II, an LLC but treated as a partnership for Federal

income tax purposes, is owned by IO, an S corporation, and F, an

individual. F owns 100 percent of the outstanding stock in IO,

70 percent of the outstanding stock of IE, an S corporation, and

63 percent of the outstanding stock of IP, a C…

2Cases cited3 opinions

  1. Callahan v. CommissionerUnited States Tax Court · 1992
  2. Hga Cinema Trust, Burton W. Kanter, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
  3. IPO II v. Comm'rUnited States Tax Court · 2004

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