Hambrose Leasing 1984-5 Ltd. Partnership v. Commissioner
United States Tax Court
By notices of final partnership administrative adjustment (FPAA's), R disallowed certain deductions claimed by the Hambrose Leasing 1984-5 and Hambrose Leasing 1984-2 Limited Partnerships. R conceded all issues raised in the FPAA's. In an amendment to her answer, R raised the applicability of sec. 465(b)(4), I.R.C., to the individual partners' personal assumptions of partnership liabilities.
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By notices of final partnership administrative adjustment (FPAA's), R disallowed certain deductions claimed by the Hambrose Leasing 1984-5 and Hambrose Leasing 1984-2 Limited Partnerships. R conceded all issues raised in the FPAA's. In an amendment to her answer, R raised the applicability of sec. 465(b)(4), I.R.C., to the individual partners' personal assumptions of partnership liabilities. P, the tax matters partner of both partnerships, conceded the nonrecourse character of the partnerships' debt. Held, the determination of a partner's amount "at risk" with respect to partnership…
1Opinion of the Court
OPINION
TANNENWALD, Judge:
By notices of final partnership administrative adjustment (fpaa), respondent disallowed certain deductions claimed by Hambrose Leasing 1984-5 Limited Partnership and Hambrose Leasing 1984-2 Limited Partnership1 for depreciation, guaranteed payments, office expenses, and interest expenses for the partnerships’ 1984 taxable year.
Respondent has conceded all of the issues raised in the FPAA’s but by amendment to answers has raised the issue of the applicability of the at-risk provisions of section 465(b)(4).2 That issue presents jurisdictional as well as substantive…
2Cases cited8 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Dial USA, Inc. v. CommissionerUnited States Tax Court · 1990
- Roberts v. CommissionerUnited States Tax Court · 1990
- Krause v. CommissionerUnited States Tax Court · 1989
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- Prati v. United StatesUnited States Court of Federal Claims · 2008
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