Legal Opinion
William Young Ruby Young v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided January 16, 1991No. 89-70384PublishedCited by 3 opinions
1Opinion of the Court
HUG, Circuit Judge:
Appellants William and Ruby Young (“taxpayers”) appeal the Tax Court order disallowing the allocation of 75% of the tax losses of Riverfront Associates, Ltd. (“Riverfront”), to one partner, Spokane Hotel Associates, Ltd. (“Spokane”) on grounds that the allocation lacked economic substance. On appeal, taxpayers contend it was clear error for the Tax Court to find that the allocation lacked economic substance. We affirm.
BACKGROUND
We highlight the following key facts and terms of the Riverfront partnership agreement. Taxpayers became limited partners in Spokane. Spokane, in…
2Cases cited8 opinions
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Ruidoso Racing Association, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Orrisch v. CommissionerUnited States Tax Court · 1970
- Joe T. Boynton and Helen J. Boynton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Goldfine v. CommissionerUnited States Tax Court · 1983
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Bankers Life and Casualty Company v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Oregon State University Alumni Association, Inc. v. Commissioner of Internal Revenue Service, Alumni Association of the University of Oregon, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1999
- Oregon State University Alumni Ass'n v. CommissionerCourt of Appeals for the Ninth Circuit · 1999