Legal Opinion

Finoli v. Commissioner

United States Tax Court

Decided April 16, 1986No. Docket Nos. 15845-82, 15915-82PublishedCited by 69 opinions

Petitioner-husband was a limited partner in a limited partnership formed in 1976 for the purpose of acquiring and exploiting a community antenna television (CATV) system located in Brooksville City and parts of Hernando County, Florida.

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Petitioner-husband was a limited partner in a limited partnership formed in 1976 for the purpose of acquiring and exploiting a community antenna television (CATV) system located in Brooksville City and parts of Hernando County, Florida. The partnership, through its general partner, entered into agreements with BFM and its affiliates BCM and NCF, pursuant to the terms of which (1) the partnership acquired the equipment used in connection with the operation of the CATV system, the franchises, a warranty on the equipment, and a list of subscribers to the system, (2) BFM agreed not to compete…

1Opinion of the Court

H3RNER, Judge:

In these consolidated cases, respondent determined deficiencies in Federal income tax against petitioners as follows:

TYE Dec. 31 Deficiency

1976 .. $32,481.76

1977 .. 16,633.00

1978 ... 27,725.36

1979 .. 26,426.88

After concessions, the issues presented for decision are: (1) Whether petitioners are entitled to deductions claimed as their distributive share of the losses of Brooksville Properties, a New Jersey limited partnership, for the years in issue; and (2) whether petitioners are entitled to an investment tax credit, representing their distributive share of the investment tax…

2Cases cited28 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Dreicer v. CommissionerUnited States Tax Court · 1982
  4. Golanty v. CommissionerUnited States Tax Court · 1979
  5. Malat v. RiddellSupreme Court of the United States · 1966

23 more not listed; retrieve them via the Exa API.

3Cited by69 opinions

  1. Antonides v. CommissionerUnited States Tax Court · 1988
  2. Stanley Works v. CommissionerUnited States Tax Court · 1986
  3. Bales v. CommissionerUnited States Tax Court · 1989
  4. Canterbury v. CommissionerUnited States Tax Court · 1992
  5. Schachter v. CommissionerUnited States Tax Court · 1994

64 more not listed; retrieve them via the Exa API.

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