James v. Commissioner
United States Tax Court
Ps are members of a joint venture (JV). JV purported to purchase from one of a group of related companies (the Communications Group) certain computer equipment subject to existing leases. The Communications Group had purchased the computer equipment at issue from the manufacturers, arranged third-party lender financing for the equipment, and leased the equipment.
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Ps are members of a joint venture (JV). JV purported to purchase from one of a group of related companies (the Communications Group) certain computer equipment subject to existing leases. The Communications Group had purchased the computer equipment at issue from the manufacturers, arranged third-party lender financing for the equipment, and leased the equipment. After selling the equipment subject to the leases to JV, the Communications Group managed the leases as JV's "agent" and charged JV implementation, management, and performance fees. By virtue of agreements between JV and the…
1Opinion of the Court
WILLIAMS, Judge:
In these consolidated cases, the Commissioner determined deficiencies in petitioners’ Federal income taxes and additions to tax for the taxable years 1979, 1980, and 1981, in the following amounts:
Docket No. Petitioner Sec. 6653(a) additions to tax Year Deficiency
27360-83 Jack S. and Carol N. James 1979 $349,785.90
29714-84 Jack S. and Carol N. James 1980 397,201.90 1981 269,325.97
33287-83 Glen E. and Sybil H. Michael 1979 211,680.00 1980 297,691.00 1981 230,108.50
24045-84 David G. and Kathleen Ownby 1980 12,214.00 1981 10,798.00
30508-84 A. F. Boudreau, Jr., and Katherine F.…
2Cases cited8 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Rice's Toyota World, Inc. v. CommissionerUnited States Tax Court · 1983
- Falsetti v. CommissionerUnited States Tax Court · 1985
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3Cited by78 opinions
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- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
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