Alexander v. Comm'r
United States Tax Court
The Court filed its opinion in this case at T.C. Memo. 1990-141. Ps were limited partners in certain partnerships involved in computer software development. We held that the payees of certain promissory notes issued by the partnerships held interests in the partnerships, other than interests as creditors, under sec. 465(b)(3)(A). R moved for reconsideration, calling into question whether sec. 465(b)(3)(A) applies to the activities of the partnerships.
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The Court filed its opinion in this case at T.C. Memo. 1990-141. Ps were limited partners in certain partnerships involved in computer software development. We held that the payees of certain promissory notes issued by the partnerships held interests in the partnerships, other than interests as creditors, under sec. 465(b)(3)(A). R moved for reconsideration, calling into question whether sec. 465(b)(3)(A) applies to the activities of the partnerships. Held: The partnerships were not engaged in the activity of leasing sec. 1245 property, under sec. 465(c)(1)(C). The partnerships were engaged…
1Opinion of the Court
Charles F. Alexander and Yvette M. Alexander, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Alexander v. Comm'r
Docket Nos. 15015-86, 18367-86, 18488-86, 20205-86, 20291-86, 20341-86, 20342-86, 20387-86, 20388-86, 20389-86, 20403-86, 20404-86, 20405-86, 20450-86, 20457-86, 20476-86, 20478-86, 20497-86, 20498-86, 20852-86, 20875-86, 20915-86, 20944-86, 20945-86, 20946-86, 20947-86, 21018-86, 21084-86, 21085-86, 21097-86, 21099-86, 21100-86, 21101-86, 21102-86, 21382-86, 21434-86, 21473-86, 21483-86
United States Tax Court
95 T.C. 467; 1990 U.S. Tax Ct. LEXIS 102; 95 T.C.…
Also in this document: Concurrence · Swift; Concurrence · Halpern.
2Cases cited18 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Waddell v. CommissionerUnited States Tax Court · 1986
- Jackson v. CommissionerUnited States Tax Court · 1986
- Warner R. Waddell and Jeanette I. Waddell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
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