Countryside, L.P. v. Comm'r
United States Tax Court
CS, a limited partnership, owned real property R, which CS sold in April of year 2. W and C were members of CS. In late year 1, CS redeemed W's and C's interests in CS by distributing to them its 99-percent interest in a (newly formed) L.L.C., CLPP, which held a99-percent interest in a second (newly formed) L.L.C., MP.
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CS, a limited partnership, owned real property R, which CS sold in April of year 2. W and C were members of CS. In late year 1, CS redeemed W's and C's interests in CS by distributing to them its 99-percent interest in a (newly formed) L.L.C., CLPP, which held a99-percent interest in a second (newly formed) L.L.C., MP. MP owned four privately issued promissory notes in the aggregate principal amount of $ 11.9 million purchased with (1) an $ 8.55 million bank loan to CS,the proceeds of which were contributed by it to CLPP, which then contributed $ 8.5 million to MP, and (2) a $ 3.4 million…
1Opinion of the Court
COUNTRYSIDE LIMITED PARTNERSHIP, CLP HOLDINGS, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Countryside, L.P. v. Comm'r
No. 3162-05
United States Tax Court
T.C. Memo 2008-3; 2008 Tax Ct. Memo LEXIS 3; 95 T.C.M. (CCH) 1006;
January 2, 2008, Filed
CS, a limited partnership, owned real property R, which CS sold in April of year 2. W and C were members of CS. In late year 1, CS redeemed W's and C's interests in CS by distributing to them its 99-percent interest in a (newly formed) L.L.C., CLPP, which held a99-percent interest in a second (newly formed) L.L.C.,…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Goldstein v. CommissionerUnited States Tax Court · 1965
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