Richardson v. Commissioner
United States Tax Court
During 1974, 1975, and 1976, petitioners were partners in three partnerships that owned and operated apartment projects. When the partnerships ran into difficulty in meeting their monthly mortgage payments and other ordinary operating expenses, new investors were sought. On Dec. 30, 1974, several individuals were admitted into each partnership, together owning a 75-percent capital interest in each partnership.
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During 1974, 1975, and 1976, petitioners were partners in three partnerships that owned and operated apartment projects. When the partnerships ran into difficulty in meeting their monthly mortgage payments and other ordinary operating expenses, new investors were sought. On Dec. 30, 1974, several individuals were admitted into each partnership, together owning a 75-percent capital interest in each partnership. Furthermore, the new partners were given a 99-percent interest in the profits and losses of each partnership for 1974 and declining percentages in the following years. Held: Sec.…
1Opinion of the Court
Sterrett, Judge:
By statutory notices dated March 29, 1978 (docket No. 5808-78), and June 18, 1979 (docket Nos. 12362-79 and 12363-79), respondent determined deficiencies in petitioners’ income taxes for the taxable years ended December 31,1974, and December 31,1976, as follows:
Docket No. Petitioner Year Deficiency
5808-78 Cecil R. Richardson and Doris C. Richardson.1974 $5,120.16
12362-79 George Schneider, Jr., and Marianne Schneider.1974 9,390.00
1976 762.00
12363-79 Irwin J. Rice and Martha J. Rice.1974 11,402.00
By an amendment to answer, filed after trial, respondent seeks an additional…
2Cases cited10 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Key Buick Co. v. CommissionerUnited States Tax Court · 1977
- Key Buick Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
- Moore v. CommissionerUnited States Tax Court · 1978
5 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- United States v. F. Thomas Little, United States of America v. Peter Chernik, United States of America v. Harold GrutchfieldCourt of Appeals for the Ninth Circuit · 1985
- Johnsen v. CommissionerUnited States Tax Court · 1984
- Smith v. CommissionerUnited States Tax Court · 1985
- Thomas v. CommissionerUnited States Tax Court · 1989
- Roccaforte v. CommissionerUnited States Tax Court · 1981
24 more not listed; retrieve them via the Exa API.