Levin v. Commissioner
United States Tax Court
Ps were limited partners in Israeli partnerships formed in December 1979 to develop, manufacture, and market certain food-packaging machinery systems. Each partnership executed, on the same day, a development agreement, a manufacturing agreement, and a marketing agreement with respect to each system.
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Ps were limited partners in Israeli partnerships formed in December 1979 to develop, manufacture, and market certain food-packaging machinery systems. Each partnership executed, on the same day, a development agreement, a manufacturing agreement, and a marketing agreement with respect to each system. Under the development agreements, the partnerships agreed to pay D, an Israeli corporation, certain amounts, stated in Israeli currency, to develop the systems into manufacturable and marketable products. Approximately one-fourth of the development fees was payable immediately in cash. The…
1Opinion of the Court
SIMPSON, Judge-.
The Commissioner determined deficiencies in the petitioners’ Federal income taxes for 1979 as follows:
Docket No. Petitioner Deficiency
19971-83 Bernard A. and Phyllis Levin $18,633
19999-83 Alan and Delores Hrabosky 61,976
The issues for decision are: (1) Whether the expenditures by certain partnerships formed for the stated purpose of developing, manufacturing, and marketing certain food-packaging machinery were paid or incurred in connection with a trade or business within the meaning of section 174 of the Internal Revenue Code of 19541; and (2) whether the interest on certain…
2Cases cited25 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Snow v. CommissionerSupreme Court of the United States · 1974
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3Cited by73 opinions
- Krause v. CommissionerUnited States Tax Court · 1992
- Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
- Smith v. CommissionerUnited States Tax Court · 1988
- Dean B. Smith and Irma Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Diamond v. CommissionerUnited States Tax Court · 1989
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