Brand v. Commissioner
United States Tax Court
Petitioners were limited partners in various limited partnerships (the partnerships) which were engaged together in a joint farming venture with another limited partnership. Petitioners guaranteed repayment of certain loans taken out by the partnerships for the benefit of the joint venture. For the years in issue, petitioners deducted losses of the partnerships in excess of their cash contributions to the partnerships.
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Petitioners were limited partners in various limited partnerships (the partnerships) which were engaged together in a joint farming venture with another limited partnership. Petitioners guaranteed repayment of certain loans taken out by the partnerships for the benefit of the joint venture. For the years in issue, petitioners deducted losses of the partnerships in excess of their cash contributions to the partnerships. Held, petitioners were not at risk under sec. 465(b), I.R.C. 1954, for the amount of partnerships' loans they guaranteed; thus, they may not deduct losses of the partnership in…
1Opinion of the Court
Hugh M. Brand and Elizabeth G. Brand, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Brand v. Commissioner
Docket Nos. 11106-80, 12326-80, 12330-80, 12331-80, 9430-81, 10022-81, 11894-81, 16923-81, 17393-81
United States Tax Court
81 T.C. 821; 1983 U.S. Tax Ct. LEXIS 15; 81 T.C. No. 50;
October 31, 1983, Filed
Decisions will be entered under Rule 155.
Petitioners were limited partners in various limited partnerships (the partnerships) which were engaged together in a joint farming venture with another limited partnership. Petitioners guaranteed repayment of certain loans taken…
2Cases cited12 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Johnny R. Austad and Dorothy Austad, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1967
- MacK Financial Corp. v. ScottIdaho Supreme Court · 1980
- Brand v. CommissionerUnited States Tax Court · 1983
- The Equitable Trust Company v. Bratwursthaus Management Corporation, and Francis J. Plombon and Patricia A. PlombonCourt of Appeals for the Fourth Circuit · 1975
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