Harbor Cove Marina Ptnrs. P'ship v. Comm'r
United States Tax Court
H is a general partnership, its managing partner is S, and its other two partners are M and P. H's business activity is primarily the operation of a marina in San Diego, California.
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H is a general partnership, its managing partner is S, and its other two partners are M and P. H's business activity is primarily the operation of a marina in San Diego, California. On account of dissension that consistently occurred between S and P as to H's operation of the marina, S, in its capacity as H's managing partner, dissolved H, distributed the marina to S or to an S affiliate, distributed to P a check in the amount of the value of P's interest in H as ascertained using a $ 16.5 million appraised value for the marina, and reported to R that H had terminated. S's actions, all of…
1Opinion of the Court
OPINION
Laro, Judge:
This case is a partnership proceeding subject to the unified audit and litigation procedures of the Tax Equity & Fiscal Responsibility Act of 1982 (tefra), Pub. L. 97-248, 96 Stat. 324, 628. It is currently before the Court for decision without trial. See Rule 122; see also sec. 6226(b).1 When the tax matters partner of Harbor Cove Marina Partners (hcmp) did not petition this Court under section 6226(a) within the 90-day period stated therein, Robert A. Collins (Collins), a notice partner of HCMP, petitioned the Court under section 6226(b) to readjust partnership items…
2Cases cited19 opinions
- Grosso v. United StatesSupreme Court of the United States · 1968
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Foxman v. CommissionerUnited States Tax Court · 1964
- Abel Kaplan and Mary Lou Kaplan v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Neubecker v. CommissionerUnited States Tax Court · 1975
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- Wise Guys Holdings, LLC v. Comm'rUnited States Tax Court · 2013
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