Abramson v. Commissioner
United States Tax Court
Held, partnership's purchase and distribution of film was an activity engaged in for profit where the purchase price was determined through arm's-length negotiations and distribution efforts resulted in the expenditure of substantial sums of money. Held, further, limited partner's pro rata guarantee of partnership's nonrecourse obligation entitles limited partner to include pro rata portion of obligation in his partnership basis.
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Held, partnership's purchase and distribution of film was an activity engaged in for profit where the purchase price was determined through arm's-length negotiations and distribution efforts resulted in the expenditure of substantial sums of money. Held, further, limited partner's pro rata guarantee of partnership's nonrecourse obligation entitles limited partner to include pro rata portion of obligation in his partnership basis. Held, further, limited partner's pro rata guarantee of partnership's nonrecourse obligation entitles limited partner to include pro rata portion of obligation in his…
1Opinion of the Court
WHITAKER, Judge:
This consolidated case includes 10 different petitioners, one of which is a fiscal year corporation. Appendix A sets forth the petitioners by name and docket numbers, the tax years involved, the deficiencies for each year, the places of residence of each individual petitioner, and the principal place of business of the corporate petitioner when each petition was filed. Each of the petitions includes, among other issues, the common issue of the tax consequences of the investment by the individual general partner and by all of the limited partners in a New Jersey limited…
2Cases cited22 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Golanty v. CommissionerUnited States Tax Court · 1979
- 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
- Siegel v. CommissionerUnited States Tax Court · 1982
17 more not listed; retrieve them via the Exa API.
3Cited by185 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Antonides v. CommissionerUnited States Tax Court · 1988
- Cherin v. CommissionerUnited States Tax Court · 1987
- Levy v. CommissionerUnited States Tax Court · 1988
- Gefen v. CommissionerUnited States Tax Court · 1986
180 more not listed; retrieve them via the Exa API.