Legal Opinion
Polakof v. Commissioner
Court of Appeals for the Ninth Circuit
Decided June 22, 1987No. Nos. 85-7581 to 85-7583, 85-7585 to 85-7587, 86-7312PublishedCited by 41 opinions
1Per curiam
Petitioners are limited partners in one or more partnerships organized by Cinema Financial of America, Inc. (CFA) as general partner. The limited partnerships acquired feature-length motion pictures from CFA for distribution. Early investor tax benefits were a major selling point in CFA’s offerings for partnership interests; acquisition was financed through large nonrecourse notes payable from a percentage of net distribution receipts. Each petitioner-taxpayer claimed distributive shares of losses and investments for tax credit purposes.
The Commissioner of Internal Revenue disallowed the…
2Cases cited14 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Narver v. CommissionerUnited States Tax Court · 1980
9 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Hulter v. CommissionerUnited States Tax Court · 1988
- Krause v. CommissionerUnited States Tax Court · 1992
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
36 more not listed; retrieve them via the Exa API.