Legal Opinion

Katz v. Commissioner

United States Tax Court

Decided January 12, 2001No. 460-96; No. 780-97; No. 181-98Published

P-H, a calendar year taxpayer, owned interests in several calendar year partnerships. P-H filed a bankruptcy petition on July 5, 1990. P-H included the portions of his distributive shares attributable to the period prior to his bankruptcy filing on his separately filed 1990 income tax return. The remainder of those distributive shares were reported by P-H's bankruptcy estate.

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P-H, a calendar year taxpayer, owned interests in several calendar year partnerships. P-H filed a bankruptcy petition on July 5, 1990. P-H included the portions of his distributive shares attributable to the period prior to his bankruptcy filing on his separately filed 1990 income tax return. The remainder of those distributive shares were reported by P-H's bankruptcy estate. HELD: The manner in which the distributive share of a partner in bankruptcy is allocated between the partner and the bankruptcy estate is not a "partnership item" under sec. 6231(a)(3), I.R.C. Accordingly, such…

1Opinion of the Court

ARON B. KATZ AND PHYLLIS A. KATZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Katz v. Commissioner

No. 460-96; No. 780-97; No. 181-98

United States Tax Court

116 T.C. 5; 2001 U.S. Tax Ct. LEXIS 2; 116 T.C. No. 2; 2001-1 U.S. Tax Cas. (CCH) P54,207;

January 12, 2001, Filed

An appropriate order will be issued denying petitioners' motion to dismiss, denying petitioners' motion for summary judgment, and granting respondent's motion for summary judgment, and decisions will be entered under Rule 155.

P-H, a calendar year taxpayer, owned interests in several

calendar year partnerships. P-H…

2Cases cited14 opinions

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Maxwell v. CommissionerUnited States Tax Court · 1986
  4. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
  5. GAF Corp. v. CommissionerUnited States Tax Court · 2000

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