Honodel v. Commissioner
United States Tax Court
Petitioners were limited partners in partnerships which acquired apartment complexes. The apartment complexes were depreciated on a component basis using useful lives as determined by the partnerships' respective general partners. The determination of useful lives was predicated on petitioners' desired rate of return on investment which took into consideration, inter alia, income tax effects to the investors.
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Petitioners were limited partners in partnerships which acquired apartment complexes. The apartment complexes were depreciated on a component basis using useful lives as determined by the partnerships' respective general partners. The determination of useful lives was predicated on petitioners' desired rate of return on investment which took into consideration, inter alia, income tax effects to the investors. Further, petitioners paid nonrefundable monthly fees to a corporation for investment advice and one-shot investment fees to the corporation for services rendered in connection with the…
1Opinion of the Court
Sterrett, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes and additions to tax:
Calendar Docket No. Petitioner year Deficiency Addition to tax under sec. 6653(a)
3843-78 Robert C. Honodel 4522-79 and Claire E. Honodel .1973 $7,314.00
1975 4,090.12
3844r-78 Lawrence E. Thatcher and Helen F. Thatcher .1973 15,669.00
3845-78 Ernest M. Bargmeyer and Janice L. Bargmeyer .1972 17,991.04
1973 14,350.45
4098-78 Conrad J. Knowles and Concetta Knowles .1972 8,501.68
1973 11,465.12
4099-78 Glen L. Momberger and Nanieve G. Momberger .1972…
2Cases cited17 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. GilmoreSupreme Court of the United States · 1963
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Helvering v. WinmillSupreme Court of the United States · 1938
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3Cited by26 opinions
- A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
- Estate of Boyd v. CommissionerUnited States Tax Court · 1981
- A.E. Staley Mfg. Co. v. CommissionerUnited States Tax Court · 1995
- Wisconsin Psychiatric Services, Ltd. v. CommissionerUnited States Tax Court · 1981
- American Stores Co. v. CommissionerUnited States Tax Court · 2000
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