Citron v. Commissioner
United States Tax Court
P borrowed $ 60,000 and, along with three other limited partners, invested in a partnership (V) in order to produce a motion picture.
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P borrowed $ 60,000 and, along with three other limited partners, invested in a partnership (V) in order to produce a motion picture. The general partner was a corporation (C). The motion picture was made by use of the capital invested by the limited partners and no debt was incurred by V. Upon completion, the negative came into the possession of the executive producer (an unrelated third party which had certain rights in it). Controversy arose over possession of the negative, and V was unable to obtain the negative. V had a copy of the film (from which only poor quality copies could be made)…
1Opinion of the Court
B. PHILIP CITRON AND EMILY K. CITRON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Citron v. Commissioner
Docket No. 626-88
United States Tax Court
97 T.C. 200; 1991 U.S. Tax Ct. LEXIS 71; 97 T.C. No. 12;
August 5, 1991, Filed
Decision will be entered under Rule 155.
P borrowed $ 60,000 and, along with three other limited partners, invested in a partnership (V) in order to produce a motion picture. The general partner was a corporation (C). The motion picture was made by use of the capital invested by the limited partners and no debt was incurred by V. Upon completion, the negative…
Also in this document: Dissent.
2Cases cited38 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Burnet v. HoustonSupreme Court of the United States · 1931
- Boehm v. CommissionerSupreme Court of the United States · 1945
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