Samis v. Commissioner
United States Tax Court
Petitioners are partners in a limited partnership which owns a "total energy plant." The sole business of the plant is to supply domestic hot water and hot and cold water for heating and air-conditioning to an apartment complex owned by KF-IDS, a joint venture in which petitioners have no ownership interest.
Read the full summary
Petitioners are partners in a limited partnership which owns a "total energy plant." The sole business of the plant is to supply domestic hot water and hot and cold water for heating and air-conditioning to an apartment complex owned by KF-IDS, a joint venture in which petitioners have no ownership interest. The total energy plant consists of two principal components owned by the partnership: (1) A concrete block structure containing gas fired boilers, refrigeration equipment, related equipment, pumps, office space for personnel, and space for plant expansion, and (2) buried pipes leading…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined deficiencies in petitioners’ income taxes as set forth below:
Year ended Deficiency
James M. and Shirley A. Samis.Dec. 31, 1972 $12,205.00
William L., Jr., and Marjorie Howard.Dec. 31, 1972 3,003.00
Estate of J. Howard Edmondson, deceased, Jeanette Edmondson, executrix.Feb. 28, 1974 1,336.31
James Samis, William Howard, Jr., and Jeanette Edmondson, executrix, are members of a limited partnership, Whispering Hills Energy, Ltd., which in 1972 acquired a total energy plant to furnish hot and chilled water for an apartment complex constructed by a joint…
2Cases cited12 opinions
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Kimmelman v. CommissionerUnited States Tax Court · 1979
- The Kramertown Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Moore v. CommissionerUnited States Tax Court · 1972
7 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Piggly Wiggly Southern, Inc. v. CommissionerUnited States Tax Court · 1985
- Illinois Cereal Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Fife v. CommissionerUnited States Tax Court · 1984
- Munford, Inc. v. CommissionerUnited States Tax Court · 1986
13 more not listed; retrieve them via the Exa API.