Harbor Cove Marina Ptnrs. P'ship v. Comm'r
United States Tax Court
H is a general partnership, its managing partner is S, and its other two partners are M and P. H's business activity is primarily the operation of a marina in San Diego, California.
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H is a general partnership, its managing partner is S, and its other two partners are M and P. H's business activity is primarily the operation of a marina in San Diego, California. On account of dissension that consistently occurred between S and P as to H's operation of the marina, S, in its capacity as H's managing partner, dissolved H, distributed the marina to S or to an S affiliate, distributed to P a check in the amount of the value of P's interest in H as ascertained using a $ 16.5 million appraised value for the marina, and reported to R that H had terminated. S's actions, all of…
1Opinion of the Court
HARBOR COVE MARINA PARTNERS PARTNERSHIP, ROBERT A. COLLINS, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Harbor Cove Marina Ptnrs. P'ship v. Comm'r
No. 13267-02
United States Tax Court
123 T.C. 64; 2004 U.S. Tax Ct. LEXIS 29; 123 T.C. No. 4;
July 15, 2004, Filed
Decision was entered for Petitioner.
H is a general partnership, its managing partner is S, and
its other two partners are M and P. H's business activity is
primarily the operation of a marina in San Diego, California. On
account of dissension that consistently occurred between S and P
a…
2Cases cited19 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Foxman v. CommissionerUnited States Tax Court · 1964
- Abel Kaplan and Mary Lou Kaplan v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Neubecker v. CommissionerUnited States Tax Court · 1975
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
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