Middleton v. Commissioner
United States Tax Court
Petitioners were limited partners in Madison. During 1973, Madison purchased essentially undeveloped acreage in Morgan County, Ga., by a combination of cash, assuming existing mortgages, and making purchase-money mortgages, all of which were nonrecourse. The properties were held by the partnership for investment.
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Petitioners were limited partners in Madison. During 1973, Madison purchased essentially undeveloped acreage in Morgan County, Ga., by a combination of cash, assuming existing mortgages, and making purchase-money mortgages, all of which were nonrecourse. The properties were held by the partnership for investment. As a result of the recession of 1974-75 which depreciated land values in Georgia, the fair market value of the various properties decreased substantially below the amounts due on the mortgages. In 1975 and 1976, the partnership determined that various parcels were worthless. The…
1Opinion of the Court
OPINION
Nims, Judge:
In the statutory notice of deficiency, respondent determined deficiencies in petitioners’ income tax for the years 1975 and 1976 in the respective amounts of $2,770.07 and $2,312.07. On June 17, 1980, this Court granted respondent leave to file an amendment to his answer, and, as a result, the deficiencies for 1975 and 1976 were increased to $3,895.30 and $3,924.15. The issues for decision are: (1) Whether petitioners’ partnership sustained losses upon each mortgage foreclosure of 5 tracts of land or upon an earlier abandonment of the properties; and (2) whether these…
2Cases cited11 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Crane v. CommissionerSupreme Court of the United States · 1947
- Gerhard v. StephensCalifornia Supreme Court · 1968
- Rhodes v. CommissionerCourt of Appeals for the Sixth Circuit · 1939
- Freeland v. CommissionerUnited States Tax Court · 1980
6 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Citron v. CommissionerUnited States Tax Court · 1991
- James W. Yarbro and Mary E. Yarbro v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1984
- Vickers v. CommissionerUnited States Tax Court · 1983
- John C. Echols and Deanna O. Echols v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Echols v. CommissionerUnited States Tax Court · 1989
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