Bailey v. Commissioner
United States Tax Court
Petitioner-husbands claimed deductions and investment tax credits in connection with motion pictures through their interests as limited partners in either of two partnerships. Held: 1. The partnerships did not acquire depreciable interests in the motion pictures but purchased contractual rights to payments contingent on the success of the respective motion picture.
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Petitioner-husbands claimed deductions and investment tax credits in connection with motion pictures through their interests as limited partners in either of two partnerships. Held: 1. The partnerships did not acquire depreciable interests in the motion pictures but purchased contractual rights to payments contingent on the success of the respective motion picture. Durkin v. Commissioner, 87 T.C. 1329 (1986), and Tolwinsky v. Commissioner, 86 T.C. 1009 (1986), followed. 2. The partnerships are entitled to depreciate their bases in the contractual rights and their bases are determined. 3. The…
1Opinion of the Court
OPINION
SCOTT, Judge:
These cases were assigned to and heard by Special Trial Judge John J. Pajak, pursuant to the provisions of section 7456 (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) of the Code and Rule 180 et seq.2 The Court agrees with and adopts the Special Trial Judge’s opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge:
In these consolidated cases,3 Respondent determined deficiencies in Federal income taxes due from petitioners as follows:
Petitioners Docket No. Taxable year…
2Cases cited52 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corliss v. BowersSupreme Court of the United States · 1930
- Knetsch v. United StatesSupreme Court of the United States · 1960
47 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman and Miriam Neuman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
- Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Markin v. CommissionerUnited States Tax Court · 1989
- Golden v. CommissionerUnited States Tax Court · 1989
- United Fibertech, Ltd. v. CommissionerUnited States Tax Court · 1991
15 more not listed; retrieve them via the Exa API.