Flowers v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Crane v. CommissionerSupreme Court of the United States · 1947
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Brannen v. CommissionerUnited States Tax Court · 1982
14 more not listed; retrieve them via the Exa API.
3Cited by211 opinions
- Beck v. CommissionerUnited States Tax Court · 1985
- Rose v. CommissionerUnited States Tax Court · 1987
- Surloff v. CommissionerUnited States Tax Court · 1983
- Patin v. CommissionerUnited States Tax Court · 1987
- Abramson v. CommissionerUnited States Tax Court · 1986
206 more not listed; retrieve them via the Exa API.