Cozzi v. Commissioner
United States Tax Court
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…
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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
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. JanisSupreme Court of the United States · 1976
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
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