Hulter v. Commissioner
United States Tax Court
A limited partnership purported to invest in real property in North Carolina. Held: 1. Ownership of the real property was not transferred to the partnership. 2. A purported $ 24.5 million nonrecourse mortgage debt obligation did not represent genuine indebtedness. 3. The real estate investment activities of the partnership were not engaged in for profit.
1Opinion of the Court
SWIFT, Judge:
In timely statutory notices of deficiency, respondent determined deficiencies in petitioners’ Federal income tax liabilities as follows:
Petitioners Henry N. and Marilyn Hulter
Year Docket No. Deficiency
1974 23116-81 $158.00
1975 3969-81 10,931.00
1976 3969-81 22,142.00
1977 3969-81 89,739.00
1978 23116-81 . 31,136.00
1979 36790-84 92,081.00
Petitioners David and Ilserose Bryan
Year Docket No. Deficiency
1975 40130-84 $13,179.00
1976 40130-84 15,711.83
1977 40130-84 16,034.77
1978 40130-84 12,510.34
1979 40130-84 28,577.63
These consolidated cases are test cases for investors who were denied…
2Cases cited46 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
41 more not listed; retrieve them via the Exa API.
3Cited by96 opinions
- Levy v. CommissionerUnited States Tax Court · 1988
- Krause v. CommissionerUnited States Tax Court · 1992
- Sheldon v. Comm'rUnited States Tax Court · 1990
- KING v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Jorgenson v. CommissionerUnited States Tax Court · 2000
91 more not listed; retrieve them via the Exa API.