Siegel v. Commissioner
United States Tax Court
Petitioners purchased a 4.95- and 9.9-percent limited interest, respectively, in a partnership in the fall of 1974. Prior to that time, the general partner, on behalf of the limited partnership, purchased a movie for a total of $ 900,000, consisting of $ 55,000 cash, recourse notes in the amount of $ 92,500, and a 6-percent nonrecourse note in the amount of $ 752,500, secured only by the movie.
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Petitioners purchased a 4.95- and 9.9-percent limited interest, respectively, in a partnership in the fall of 1974. Prior to that time, the general partner, on behalf of the limited partnership, purchased a movie for a total of $ 900,000, consisting of $ 55,000 cash, recourse notes in the amount of $ 92,500, and a 6-percent nonrecourse note in the amount of $ 752,500, secured only by the movie. An additional payment denoted "prepaid interest" of $ 42,500 was also made by the partnership in 1974. The general partner was actively involved in the exploitation of the film and made an extensive…
1Opinion of the Court
Scott, Judge:
In these consolidated cases, respondent determined deficiencies for the years and in the amounts as follows:
Deficiency in Year income tax Petitioners
1974 $19,529.29 Charles H. Siegel and Mary Ann G. Siegel ....
1975 7,551.53
1976 7,169.49
Edgar L. Feininger
1974 7,824.53 and Grace K. Feininger
1975 131.90
1976 3,278.00
The issues for decision are (1) whether each petitioner, as a limited partner of D. N. Co., is entitled to a claimed deduction for a distributive share of losses reported by the partnership and, if so, in what amount; and (2) whether each petitioner is entitled to a…
2Cases cited30 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
25 more not listed; retrieve them via the Exa API.
3Cited by245 opinions
- Beck v. CommissionerUnited States Tax Court · 1985
- Rose v. CommissionerUnited States Tax Court · 1987
- Flowers v. CommissionerUnited States Tax Court · 1983
- Fox v. CommissionerUnited States Tax Court · 1983
- Abramson v. CommissionerUnited States Tax Court · 1986
240 more not listed; retrieve them via the Exa API.