Legal Opinion

Flowers v. Commissioner

United States Tax Court

Decided May 16, 1983No. Docket Nos. 8315-80, 8336-80, 8417-80, 8418-80, 8419-80PublishedCited by 211 opinions

Petitioners were limited partners in a Florida limited partnership called Levon Records. In a simultaneous transaction, Chiodo-Scott sold four master recordings to Common Sense for $ 85,000 and an $ 840,000 nonrecourse promissory note, Common Sense sold the recordings to Levon Records for $ 136,500 in cash and a $ 940,000 nonrecourse note, and Levon Records leased the recordings to SRS, which was owned by the same individuals who owned Chiodo-Scott, by way of a distribution…

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Petitioners were limited partners in a Florida limited partnership called Levon Records. In a simultaneous transaction, Chiodo-Scott sold four master recordings to Common Sense for $ 85,000 and an $ 840,000 nonrecourse promissory note, Common Sense sold the recordings to Levon Records for $ 136,500 in cash and a $ 940,000 nonrecourse note, and Levon Records leased the recordings to SRS, which was owned by the same individuals who owned Chiodo-Scott, by way of a distribution agreement that obligated SRS to use its best efforts to promote and distribute the records pressed from the master…

1Opinion of the Court

Sterrett, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes as follows:

Docket No. Petitioner TYE Dec. 31-Deficiency

8315-80 George T. Flowers and Donna Flowers 1974 1976 $1,078.00 5,629.00

1977 828.00

8336-80 Cary A. Williams and Suzanne M. Williams 1976 1977 7,101.62 10,773.18

8417-80 Charles J. Crist and Nancy L. Crist 1977 4,072.75

8418-80 William J. McCallie and Charlotte W. McCallie 1976 1977 7,177.00 6,503.00

8419-80 Richard L. Peck and Evelyn K. Peck 1976 1977 7,330.41 6,347.01

After various concessions, the issues for decision are (1)…

2Cases cited19 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Golanty v. CommissionerUnited States Tax Court · 1979
  4. Engdahl v. CommissionerUnited States Tax Court · 1979
  5. Brannen v. CommissionerUnited States Tax Court · 1982

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

3Cited by211 opinions

  1. Beck v. CommissionerUnited States Tax Court · 1985
  2. Rose v. CommissionerUnited States Tax Court · 1987
  3. Surloff v. CommissionerUnited States Tax Court · 1983
  4. Patin v. CommissionerUnited States Tax Court · 1987
  5. Abramson v. CommissionerUnited States Tax Court · 1986

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

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