Sheid v. Commissioner
United States Tax Court
Held: Partnership business of owning Film constituted activity engaged in for profit; petitioners may not include face amount of nonrecourse note in basis but may include actual cash outlay; petitioners may depreciate Film pursuant to income forecast method and depreciation determined thereunder; and petitioners are not entitled to investment tax credit with respect to Film.
1Opinion of the Court
HARVEY L. SHEID AND RITA SHEID, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sheid v. Commissioner
Docket No. 5818-81, 20307-81, 20308-81, 17898-83.
United States Tax Court
T.C. Memo 1985-402; 1985 Tax Ct. Memo LEXIS 235; 50 T.C.M. (CCH) 663; T.C.M. (RIA) 85402;
August 7, 1985.
Held: Partnership business of owning Film constituted activity engaged in for profit; petitioners may not include face amount of nonrecourse note in basis but may include actual cash outlay; petitioners may depreciate Film pursuant to income forecast method and depreciation determined thereunder; and…
2Cases cited33 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. CartwrightSupreme Court of the United States · 1973
- Golanty v. CommissionerUnited States Tax Court · 1979
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
28 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Harvey Jacobson and Marcia Jacobson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
- In Re Mdl-731--Tax Refund Litigation Of Organizers And Promoters Of Investment Plans Involving Book Properties Leasing. Barrister AssociatesCourt of Appeals for the Second Circuit · 1993
- Barrister Associates v. United StatesCourt of Appeals for the Second Circuit · 1993