Legal Opinion

Cozzi v. Commissioner

United States Tax Court

Decided February 18, 1987No. Docket No. 24208-84Published

In 1975, H, a limited partnership formed to produce motion picture films, entered into an agreement with M to produce a film for M in return for annual payments in 1976 through 1981. B agreed to produce such film for H in return for certain rights to the film from M, and B agreed to make certain annual payments in 1976 through 1979 to H on behalf of M. H entered into a nonrecourse loan agreement with S, whereby H agreed to repay such loan in annual payments in 1977 through…

Read the full summary

In 1975, H, a limited partnership formed to produce motion picture films, entered into an agreement with M to produce a film for M in return for annual payments in 1976 through 1981. B agreed to produce such film for H in return for certain rights to the film from M, and B agreed to make certain annual payments in 1976 through 1979 to H on behalf of M. H entered into a nonrecourse loan agreement with S, whereby H agreed to repay such loan in annual payments in 1977 through 1980. H reported a large loss on its tax return for 1975. The film never made a profit, and none of the annual payments…

1Opinion of the Court

John R. Cozzi and Antoinette V. Cozzi, Petitioners v. Commissioner of Internal Revenue, Respondent

Cozzi v. Commissioner

Docket No. 24208-84

United States Tax Court

88 T.C. 435; 1987 U.S. Tax Ct. LEXIS 20; 88 T.C. No. 20;

February 18, 1987. February 18, 1987, Filed

Decision will be entered for the respondent.

In 1975, H, a limited partnership formed to produce motion picture films, entered into an agreement with M to produce a film for M in return for annual payments in 1976 through 1981. B agreed to produce such film for H in return for certain rights to the film from M, and B agreed to make…

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. JanisSupreme Court of the United States · 1976
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927

21 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API