Surloff v. Commissioner
United States Tax Court
Petitioners were limited partners in one of eight different limited partnerships formed in 1976 to lease and mine the coal in two tracts of land in Kentucky and Tennessee. The partnership interests were promoted and sold to petitioners by Finkel, who was the general partner in all of the partnerships, and his attorney, Beck. The petitioners paid cash for their partnership interests.
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Petitioners were limited partners in one of eight different limited partnerships formed in 1976 to lease and mine the coal in two tracts of land in Kentucky and Tennessee. The partnership interests were promoted and sold to petitioners by Finkel, who was the general partner in all of the partnerships, and his attorney, Beck. The petitioners paid cash for their partnership interests. The coal leases entered into by the partnerships required them to pay advanced royalties for most, if not all, of the coal thought to be recoverable from the properties, parts of which were payable in cash and…
1Opinion of the Court
Drennen, Judge:*
Respondent determined deficiencies in Federal income tax for the following taxpayers and for the taxable years as follows:
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After concessions, the issue for decision2 is the amount, if any, that petitioners, as limited partners, are entitled to deduct as their distributive share of the losses and interest claimed by the respective partnerships in which they were limited partners. Resolution of this issue is dependent upon the following:(1) Whether the partnerships are entitled to advanced royalty deductions;(2) Whether the partnerships are entitled to deductions…
2Cases cited33 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- United States v. SullivanSupreme Court of the United States · 1927
- Golanty v. CommissionerUnited States Tax Court · 1979
28 more not listed; retrieve them via the Exa API.
3Cited by211 opinions
- Niedringhaus v. CommissionerUnited States Tax Court · 1992
- Beck v. CommissionerUnited States Tax Court · 1985
- Antonides v. CommissionerUnited States Tax Court · 1988
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- 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
206 more not listed; retrieve them via the Exa API.