Tallal v. Commissioner
United States Tax Court
Petitioner was a limited partner in Cumberland, which was a limited partnership formed on Oct. 27, 1976, to lease and mine coal property in West Virginia. On Oct. 28, 1976, Crescent, which was controlled by the general partners of Cumberland, subleased certain coal mining rights from Black Rock and agreed to pay an advanced royalty of $2,700,000, payable $1,200,000 in cash and $1,500,000 by a nonrecourse note.
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Petitioner was a limited partner in Cumberland, which was a limited partnership formed on Oct. 27, 1976, to lease and mine coal property in West Virginia. On Oct. 28, 1976, Crescent, which was controlled by the general partners of Cumberland, subleased certain coal mining rights from Black Rock and agreed to pay an advanced royalty of $2,700,000, payable $1,200,000 in cash and $1,500,000 by a nonrecourse note. Also on Oct. 28, Cumberland subleased the same coal mining rights from Crescent, and agreed to pay Crescent an advanced royalty of $4,975,000, payable $1,975,000 in cash and $3,000,00…
1Opinion of the Court
JOSEPH J. TALLAL, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Tallal v. Commissioner
Docket No. 19237-80.
United States Tax Court
T.C. Memo 1984-486; 1984 Tax Ct. Memo LEXIS 186; 48 T.C.M. (CCH) 1082; T.C.M. (RIA) 84486;
September 11, 1984.
Petitioner was a limited partner in Cumberland, which was a limited partnership formed on Oct. 27, 1976, to lease and mine coal property in West Virginia. On Oct. 28, 1976, Crescent, which was controlled by the general partners of Cumberland, subleased certain coal mining rights from Black Rock and agreed to pay an advanced royalty of…
2Cases cited33 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dreicer v. CommissionerUnited States Tax Court · 1982
- United States v. SullivanSupreme Court of the United States · 1927
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
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