Legal Opinion

Landry v. Commissioner

United States Tax Court

Decided June 24, 1986No. Docket No. 20585-81PublishedCited by 39 opinions

P was a limited partner in W, a Texas limited partnership formed for the purpose of constructing and managing an apartment project. W contracted with J and its affiliates for the construction of the project and the provision of certain related services, guarantees, and covenants.

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P was a limited partner in W, a Texas limited partnership formed for the purpose of constructing and managing an apartment project. W contracted with J and its affiliates for the construction of the project and the provision of certain related services, guarantees, and covenants. The project was constructed in two phases, and W made downpayments to J of $ 375,000 and $ 190,000 and executed wraparound notes in favor of J for the remainder of the total purchase prices of $ 5,775,000 and $ 1,690,000 for the two phases. W allocated certain portions of the purchase prices to interest and to fees…

1Opinion of the Court

SIMPSON, Judge:

The Commissioner determined a deficiency of $18,328.69 in the petitioner’s Federal income tax for 1977. After a concession by the petitioner, the issues for decision are: (1) Whether Woodscape Associates, Ltd., a limited partnership formed to construct and operate an apartment project in 1977, was engaged in such activity for profit in that year; and (2) whether Woodscape is entitled to deductions claimed by it for the amounts of the purchase price of the apartment project allocated by it to interest and to the payment of certain fees.

FINDINGS OF FACT

Some of the facts have been…

2Cases cited53 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. Gregory v. HelveringSupreme Court of the United States · 1935
  5. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940

48 more not listed; retrieve them via the Exa API.

3Cited by39 opinions

  1. Antonides v. CommissionerUnited States Tax Court · 1988
  2. Glass v. CommissionerUnited States Tax Court · 1986
  3. Levy v. CommissionerUnited States Tax Court · 1988
  4. Hulter v. CommissionerUnited States Tax Court · 1988
  5. Levin v. CommissionerUnited States Tax Court · 1986

34 more not listed; retrieve them via the Exa API.

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