Legal Opinion
William Sennett and Sandra Sennett v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 9, 1985No. 83-7758PublishedCited by 20 opinions
1Per curiam
Taxpayers William and Sandra Sennett claimed an ordinary loss deduction of $109,-061 on their 1969 tax return. This loss represented William Sennett’s share of the ordinary losses incurred in 1968 by Professional Properties Partnership (“PPP”) when it repurchased his interest in the partnership. The Commissioner of Internal Revenue disallowed the deduction asserting inter alia that in 1969 Sennett had no basis in an interest in PPP since he had left the partnership in 1968 and is precluded by 26 U.S.C. § 704(d) and Treas.Reg. § 1.704-l(d) from claiming any loss. The Tax Court', 80 T.C. 825,…
2Cases cited4 opinions
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
- Sennett v. CommissionerUnited States Tax Court · 1978
- Sennett v. CommissionerUnited States Tax Court · 1983
3Cited by20 opinions
- Vukasovich, Inc. v. Commissioner of Internal Revenue, Vukasovich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Marcus W. Melvin and Marilyn E. Melvin v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
- Thomas Take and Janice Take v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
- Church by Mail, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Richard L. Smith Vanalco, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002
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