Legal Opinion
Donald R. Campbell and Patricia A. Campbell v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 24, 1989No. 87-1892PublishedCited by 23 opinions
1Opinion of the Court
*835MERRITT, Circuit Judge.
The primary issue in this tax case is whether a partnership, which buys an airplane and leases it to a corporation controlled by the partners, for the purpose of generating a profit in the corporation, is engaged in an activity for profit under § 183 of the Internal Revenue Code, 26 U.S.C. § 183 (1988).1 Here, the shareholders of the corporation were substantially the same as the partners, and the airplane was the partnership’s only asset. The partners contributed little or no capital to the partnership venture, and the partnership generated significant tax losses. The…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Herrick v. CommissionerUnited States Tax Court · 1985
- Ronnen v. CommissionerUnited States Tax Court · 1988
- Joseph J. Tallal, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Dean B. Smith and Irma Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Robert E. Holmes and Carolyn S. Holmes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1999
- Anthony Ranciato and Lucille Ranciato v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1995
- Hayden v. CommissionerCourt of Appeals for the Sixth Circuit · 1989
- Arrowhead Mt. Getaway v. CommissionerUnited States Tax Court · 1995
18 more not listed; retrieve them via the Exa API.