Egolf v. Commissioner
United States Tax Court
P is the general partner of a limited partnership engaged in oil and gas drilling. Pursuant to the partnership agreement, P, as general manager, provides management services to the partnership in exchange for a management fee. P paid various organization and syndication costs of the partnership and claimed them as ordinary and necessary expenses of his lease management business.
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P is the general partner of a limited partnership engaged in oil and gas drilling. Pursuant to the partnership agreement, P, as general manager, provides management services to the partnership in exchange for a management fee. P paid various organization and syndication costs of the partnership and claimed them as ordinary and necessary expenses of his lease management business. Held, the management fee P received is reimbursement for the organization and syndication expenses he paid on behalf of the partnership and he is not entitled to claim a deduction for those expenses. Sec. 709(a),…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income taxes for the taxable years 1978 and 1979 in the amounts of $112,628.52 and $392,761.80, respectively. The issues for decision are: (1) Whether petitioner properly deducted as ordinary and necessary business expenses amounts paid by him representing partnership organization and syndication costs; (2) whether the partnership may amortize organization and syndication expenses; and (3) whether management fee payments received by petitioner in excess of the amount provided in the partnership agreement represented…
2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Corliss v. BowersSupreme Court of the United States · 1930
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3Cited by7 opinions
- Green Gas Del. Statutory Trust v. Comm'rUnited States Tax Court · 2016
- Sorrell v. CommissionerUnited States Tax Court · 1987
- Collins v. CommissionerUnited States Tax Court · 1987
- Egolf v. CommissionerUnited States Tax Court · 1986
- Evans v. CommissionerUnited States Tax Court · 1994
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