Surloff v. Commissioner
United States Tax Court
Petitioners were limited partners in one of eight different limited partnerships formed in 1976 to lease and mine the coal in two tracts of land in Kentucky and Tennessee. The partnership interests were promoted and sold to petitioners by Finkel, who was the general partner in all of the partnerships, and his attorney, Beck. The petitioners paid cash for their partnership interests.
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Petitioners were limited partners in one of eight different limited partnerships formed in 1976 to lease and mine the coal in two tracts of land in Kentucky and Tennessee. The partnership interests were promoted and sold to petitioners by Finkel, who was the general partner in all of the partnerships, and his attorney, Beck. The petitioners paid cash for their partnership interests. The coal leases entered into by the partnerships required them to pay advanced royalties for most, if not all, of the coal thought to be recoverable from the properties, parts of which were payable in cash and…
1Opinion of the Court
Arthur B. Surloff and Cheri Surloff, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Surloff v. Commissioner
Docket Nos. 7306-80, 7319-80, 7324-80, 7326-80, 7338-80, 7344-80, 7353-80, 7361-80, 7379-80, 16025-80, 18308-80, 19379-80, 19381-80, 8360-81, 22074-81, 22075-81
United States Tax Court
81 T.C. 210; 1983 U.S. Tax Ct. LEXIS 48; 81 T.C. No. 17; 78 Oil & Gas Rep. 371;
August 31, 1983, Filed
Decisions will be entered under Rule 155.
Petitioners were limited partners in one of eight different limited partnerships formed in 1976 to lease and mine the coal in two tracts of land…
2Cases cited33 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- United States v. SullivanSupreme Court of the United States · 1927
- Golanty v. CommissionerUnited States Tax Court · 1979
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