Crescent Holdings, LLC v. Comm'r
United States Tax Court
Holdings was a limited liability company formed on Sept. 7, 2006, and classified as a partnership for Federal income tax purposes.
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Holdings was a limited liability company formed on Sept. 7, 2006, and classified as a partnership for Federal income tax purposes. Resources was a limited liability company whose ownership was transferred to Holdings on Sept. 7, 2006. On Sept. 7, 2006, Resources entered into an employment agreement with P to have Holdings transfer a 2% interest in Holdings to P if P served as chief executive officer (CEO) of Resources for a period of three years ending on Sept. 7, 2009. The 2% interest was subject to a substantial risk of forfeiture and was not transferable. Holdings allocated partnership…
1Opinion of the Court
Ruwe, Judge:
Respondent issued a notice of final partnership administrative adjustment (FPAA) for the taxable year 2006 and an FPAA for the taxable year 2007 to Crescent Holdings, LLC (Crescent Holdings). Arthur Fields (petitioner), a partner other than the tax matters partner, filed petitions for readjustment of partnership items under section 6226.1 The cases were consolidated for trial, briefing, and opinion.
The issues for decision are: (1) whether petitioner should be treated as a partner owning a 2% interest in Crescent Holdings for purposes of allocating its profits and losses for the…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. BlissSupreme Court of the United States · 1934
- Blonien v. Comm'rUnited States Tax Court · 2002
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
12 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Omega Forex Grp., LC v. United StatesCourt of Appeals for the Tenth Circuit · 2018
- Crescent Holdings LLC, Arthur W. & Joleen H. Fields, A Partner Other Than the Tax Matters Partner v. CommissionerUnited States Tax Court · 2013
- Crescent Holdings, LLC v. Comm'rUnited States Tax Court · 2013
- SWF Real Estate LLC v. Comm'rUnited States Tax Court · 2015