Bennion v. Commissioner
United States Tax Court
In 1979, Matrix Computer Funding Corp. (Matrix) obtained a $ 1,305,341.70 loan from a bank to purchase three IBM check sorters. Matrix leased the three check sorters back to the seller. In 1980, Matrix sold one of the check sorters to an individual named Lloyd in an arm's-length transaction. As part of the consideration for the purchase, Lloyd agreed to repay up to $ 443,009 of the $ 1,305,341.70 bank loan obtained by Matrix.
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In 1979, Matrix Computer Funding Corp. (Matrix) obtained a $ 1,305,341.70 loan from a bank to purchase three IBM check sorters. Matrix leased the three check sorters back to the seller. In 1980, Matrix sold one of the check sorters to an individual named Lloyd in an arm's-length transaction. As part of the consideration for the purchase, Lloyd agreed to repay up to $ 443,009 of the $ 1,305,341.70 bank loan obtained by Matrix. Lloyd also paid Matrix $ 35,000 cash and gave Matrix a $ 41,681 recourse promissory note. Immediately after he purchased the check sorter, Lloyd sold the check sorter to…
1Opinion of the Court
SWIFT, Judge:
In a statutory notice of deficiency dated April 13, 1984, respondent determined a deficiency in petitioners’ Federal income tax liability for 1980 in the amount of $50,028. After concessions, respondent reduced his deficiency determination to $20,364. The primary issue for decision is whether petitioner Sam H. Bennion is at risk within the meaning of section 4651 with respect to his pro rata share of the recourse debt obligations of a joint venture of which he was a member.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. Petitioner Sam H. Bennion resided…
2Cases cited17 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Frieling v. CommissionerUnited States Tax Court · 1983
- Gefen v. CommissionerUnited States Tax Court · 1986
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Mulvania v. CommissionerUnited States Tax Court · 1983
12 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Levy v. CommissionerUnited States Tax Court · 1988
- Jerry E. Pritchett and Patricia D. Pritchett v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Alexander v. Comm'rUnited States Tax Court · 1990
- Krause v. CommissionerUnited States Tax Court · 1989
- Thornock v. Comm'rUnited States Tax Court · 1990
27 more not listed; retrieve them via the Exa API.