Estate of Thomas v. Commissioner
United States Tax Court
Held, lessor partnership is true owner of computer equipment for tax purposes; petitioners may not amortize equity placement fee over life of partnership.
1Opinion of the Court
Whitaker, Judge:
This case was submitted fully stipulated pursuant to Rule 122;2 the stipulation of facts and exhibits attached thereto are incorporated herein by this reference. However, many of the facts set forth herein are based upon our examination of the exhibits and were not set out in the stipulation.
Respondent determined the following Federal income tax deficiencies:
Docket No. Petitioner Year(s) Deficiency
17715-81 Estate of Jerry Thomas (deceased) 1976 $20,449.99
Imogene Thomas, administratrix, 1977 35,831.08
and Imogene Thomas 1978 23,117.88
(The years 1978 and 1979 do not involve the…
2Cases cited52 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. BrownSupreme Court of the United States · 1965
47 more not listed; retrieve them via the Exa API.
3Cited by123 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Levy v. CommissionerUnited States Tax Court · 1988
- Gefen v. CommissionerUnited States Tax Court · 1986
118 more not listed; retrieve them via the Exa API.