Legal Opinion

Melvin v. Commissioner

United States Tax Court

Decided January 12, 1987No. Docket Nos. 9325-83, 9451-83Published

Medici, a partnership in which petitioner Marcus W. Melvin was a general partner, invested in a limited partnership. In payment for its limited partnership interest, Medici made a $ 35,000 cash downpayment and agreed to make additional capital contributions in the amount of $ 70,000. The obligation to make the additional capital contributions was reflected by a $ 70,000 recourse promissory note given to the limited partnership.

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Medici, a partnership in which petitioner Marcus W. Melvin was a general partner, invested in a limited partnership. In payment for its limited partnership interest, Medici made a $ 35,000 cash downpayment and agreed to make additional capital contributions in the amount of $ 70,000. The obligation to make the additional capital contributions was reflected by a $ 70,000 recourse promissory note given to the limited partnership. The limited partnership obtained a $ 3,500,000 recourse loan from a bank. To secure the bank loan, the limited partnership pledged to the bank, among other things, the…

1Opinion of the Court

Marcus W. Melvin and Marilyn E. Melvin, Petitioners v. Commissioner of Internal Revenue, Respondent; Marcus W. Melvin, M.D., P.C., Petitioner v. Commissioner of Internal Revenue, Respondent

Melvin v. Commissioner

Docket Nos. 9325-83, 9451-83

United States Tax Court

88 T.C. 63; 1987 U.S. Tax Ct. LEXIS 5; 88 T.C. No. 5;

January 12, 1987. January 12, 1987, Filed

Decisions will be entered under Rule 155.

Medici, a partnership in which petitioner Marcus W. Melvin was a general partner, invested in a limited partnership. In payment for its limited partnership interest, Medici made a $ 35,000 cash…

2Cases cited32 opinions

  1. Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
  2. Abramson v. CommissionerUnited States Tax Court · 1986
  3. American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
  4. Gefen v. CommissionerUnited States Tax Court · 1986
  5. United Aniline Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963

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