Levin v. Commissioner
United States Tax Court
Ps were limited partners in Israeli partnerships formed in December 1979 to develop, manufacture, and market certain food-packaging machinery systems. Each partnership executed, on the same day, a development agreement, a manufacturing agreement, and a marketing agreement with respect to each system.
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Ps were limited partners in Israeli partnerships formed in December 1979 to develop, manufacture, and market certain food-packaging machinery systems. Each partnership executed, on the same day, a development agreement, a manufacturing agreement, and a marketing agreement with respect to each system. Under the development agreements, the partnerships agreed to pay D, an Israeli corporation, certain amounts, stated in Israeli currency, to develop the systems into manufacturable and marketable products. Approximately one-fourth of the development fees was payable immediately in cash. The…
1Opinion of the Court
Bernard A. Levin and Phyllis Levin, Petitioners v. Commissioner of Internal Revenue, Respondent; Alan T. Hrabosky and Delores Y. Hrabosky, Petitioners v. Commissioner of Internal Revenue, Respondent
Levin v. Commissioner
Docket Nos. 19971-83, 19999-83
United States Tax Court
87 T.C. 698; 1986 U.S. Tax Ct. LEXIS 43; 87 T.C. No. 43;
September 29, 1986, Filed
Decisions will be entered for the respondent.
Ps were limited partners in Israeli partnerships formed in December 1979 to develop, manufacture, and market certain food-packaging machinery systems. Each partnership executed, on the same day, a…
2Cases cited26 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Snow v. CommissionerSupreme Court of the United States · 1974
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