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
William T. Egolf and Harrylou Egolf, Petitioners v. Commissioner of Internal Revenue, Respondent
Egolf v. Commissioner
Docket No. 3640-83
United States Tax Court
87 T.C. 34; 1986 U.S. Tax Ct. LEXIS 85; 87 T.C. No. 2;
July 2, 1986, Filed
Decision will be entered under Rule 155.
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…
2Cases cited24 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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