Robert L. Whitmire v. Commissioner

109 T.C. No. 13

UNITED STATES TAX COURT ROBERT L. WHITMIRE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21849-84. Filed October 29, 1997. Held: Notwithstanding the recourse nature of a third-party bank loan, due to various loss-limiting features associated with a computer equipment leasing transaction, petitioner is not to be regarded as at risk under sec. 465, I.R.C., with regard to related partnership debt obligations. Stephen D. Gardner, for petitioner. Elizabeth P. Flores, Martin L. Shindler, Marcie B. Harrison, Brian J. Condon, Victoria J. Kanrek, and David A.…