Goodwin v. Commissioner
United States Tax Court
Petitioner-husband was a partner in two limited partnerships formed to construct housing projects. Construction of the housing projects was not completed, and the units were not leased to tenants, until after 1972. Both partnerships reported deductions on their 1972 Federal income tax returns for certain loan and mortgage broker fees paid in order to arrange financing for the housing projects.
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Petitioner-husband was a partner in two limited partnerships formed to construct housing projects. Construction of the housing projects was not completed, and the units were not leased to tenants, until after 1972. Both partnerships reported deductions on their 1972 Federal income tax returns for certain loan and mortgage broker fees paid in order to arrange financing for the housing projects. Respondent disallowed petitioner's ratable share of the partnership losses for 1972 to the extent they were attributable to the various loan and broker fee deductions. Held: The partnerships were not…
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the year 1972 in the amount of $32,640.68.1 During 1972, Richard C. Goodwin was a partner in two real estate limited partnerships, the Bethlehem Development Co. and D. M. Associates, both of which were formed to construct and operate certain housing projects. Respondent disallowed his distributive share of certain expenses deducted by the partnerships. After concessions by the parties, the only issues remaining for decision are:(1) Whether certain loan and broker fees paid by the partnerships to arrange…
2Cases cited41 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. TellierSupreme Court of the United States · 1966
- Enoch v. CommissionerUnited States Tax Court · 1972
- United States v. BasyeSupreme Court of the United States · 1973
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
36 more not listed; retrieve them via the Exa API.
3Cited by98 opinions
- 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
- Antonides v. CommissionerUnited States Tax Court · 1988
- Waddell v. CommissionerUnited States Tax Court · 1986
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
93 more not listed; retrieve them via the Exa API.