Krause v. Commissioner
United States Tax Court
The parties cross move for partial summary judgment in these test cases involving partnership investments in oil and gas exploration and production.
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The parties cross move for partial summary judgment in these test cases involving partnership investments in oil and gas exploration and production. Assuming, for purposes of the instant motions only, that the partnership debt obligations are genuine, it is held, (1) that the limited partners' assumption of partnership debt obligations created amounts with respect to which the limited partners were at risk under sec. 465(b)(2), I.R.C. of 1954, but only to the extent of the fixed and definite accruals each year on the debt obligations and only to the extent of the limited partners' fixed and…
1Opinion of the Court
OPINION
Swift, Judge:
This matter is before the Court on the parties’ cross-motions for partial summary judgment filed under Rule 121.1 With one exception, the issues with respect to which each party seeks summary judgment are the same. Each party has filed an objection to the opposing party’s motion for partial summary judgment on the merits of each of the issues raised therein, and each party objects to the opposing party’s motion for partial summary judgment as to certain issues on the ground that disputed material facts exist that make summary disposition of these issues in favor of the…
2Cases cited22 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Guy v. LiederbachSupreme Court of Pennsylvania · 1983
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Jackson v. CommissionerUnited States Tax Court · 1986
17 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Krause v. CommissionerUnited States Tax Court · 1992
- Hambrose Leasing 1984-5 Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Alexander v. Comm'rUnited States Tax Court · 1990
- Moser v. CommissionerCourt of Appeals for the Eighth Circuit · 1990
- Steven G. Hill Parilea Hill v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
26 more not listed; retrieve them via the Exa API.