Greene v. Commissioner
United States Tax Court
P was a limited partner in a partnership formed to acquire and distribute a motion picture film. The partnership entered into a distribution agreement with D providing that the gross rentals from the exhibition of the film were to be deposited in a bank account from which withdrawals could be made only by the joint approval of the partnership and D. The funds were first to be used to pay certain distribution expenses incurred by D and to pay its fee for its services.
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P was a limited partner in a partnership formed to acquire and distribute a motion picture film. The partnership entered into a distribution agreement with D providing that the gross rentals from the exhibition of the film were to be deposited in a bank account from which withdrawals could be made only by the joint approval of the partnership and D. The funds were first to be used to pay certain distribution expenses incurred by D and to pay its fee for its services. In 1972 through 1976, the expenses exceeded the gross rentals. The partnership elected to compute depreciation on the film by…
1Opinion of the Court
OPINION
Simpson, Judge:
This matter is before the Court on the parties’ cross motions for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1 The sole issue raised by the motions is whether Alpha Film Co. (Alpha) is entitled to a depreciation deduction for 1975 under the income forecast method.
The Commissioner determined a deficiency of $9,195 in the petitioners’ Federal income tax for 1975. The deficiency resulted from the disallowance of the depreciation deduction claimed by Alpha and from certain other adjustments not now before us. The petitioners,…
2Cases cited9 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Siegel v. CommissionerUnited States Tax Court · 1982
- Simms v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1952
- Wildman v. CommissionerUnited States Tax Court · 1982
4 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Todd v. CommissionerUnited States Tax Court · 1987
- Law v. CommissionerUnited States Tax Court · 1985
- Durkin v. CommissionerUnited States Tax Court · 1986
- Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
25 more not listed; retrieve them via the Exa API.