Krause v. Commissioner
United States Tax Court
Petitioners invested in limited partnerships relating to, among other things, enhanced oil recovery technology. Held, on the primary issues: (1) Activities of the partnerships were not engaged in with actual and honest profit objectives, and (2) debt obligations of the partnerships were not genuine.
1Opinion of the Court
Swift, Judge:
At docket No. 33231-86, with respect to petitioners Dorothy A. Hildebrand Wahl and R.A. Hildebrand, respondent determined deficiencies in Federal income tax, increased interest, and additions to tax for 1980, 1981, and 1982, as follows:
Petitioners at Docket No. 33231-86
Dorothy A. Hildebrand Wahl
Increased interest and additions to tax
Year Deficiency Sec. 6621(c) Sec. 6653(a) Sec. 6653(a)(1) Sec. 6653(a)(2)
1980 $39,359 $1,968
1981 48,027 $2,464 2
R.A. Hildebrand
Increased interest and additions to tax
Year Deficiency See. 6621(c) See-6653(a)(1) See. 6653(a)(2) See 6659 See. 6661
1982…
2Cases cited33 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Pallottini v. CommissionerUnited States Tax Court · 1988
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
28 more not listed; retrieve them via the Exa API.
3Cited by93 opinions
- Jonson v. Comm'rUnited States Tax Court · 2002
- Ewing v. Comm'rUnited States Tax Court · 2004
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Robinette v. Comm'rUnited States Tax Court · 2004
- Corson v. CommissionerUnited States Tax Court · 2000
88 more not listed; retrieve them via the Exa API.