Legal Opinion

Golden v. Commissioner

United States Tax Court

Decided September 25, 1989No. Docket No. 21693-84UnpublishedCited by 2 opinions

Petitioner husband was a limited partner in a partnership formed to purchase the rights to certain computer software designed for internal management by small school districts and to market the software to the school districts. Petitioners claimed depreciation and investment credit for the software on their tax return. Held: (1) The partnership did not engage in a trade or business with an actual and honest objective of making a profit.

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Petitioner husband was a limited partner in a partnership formed to purchase the rights to certain computer software designed for internal management by small school districts and to market the software to the school districts. Petitioners claimed depreciation and investment credit for the software on their tax return. Held: (1) The partnership did not engage in a trade or business with an actual and honest objective of making a profit. (2) Petitioners are not entitled to claim depreciation or investment credit for the computer software. (3) Substantially all of the resulting deficiency is an…

1Opinion of the Court

MARTIN P. GOLDEN AND REGINA GOLDEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Golden v. Commissioner

Docket No. 21693-84

United States Tax Court

T.C. Memo 1989-514; 1989 Tax Ct. Memo LEXIS 514; 58 T.C.M. (CCH) 185; T.C.M. (RIA) 89514;

September 25, 1989; As corrected September 26, 1989

Petitioner husband was a limited partner in a partnership formed to purchase the rights to certain computer software designed for internal management by small school districts and to market the software to the school districts. Petitioners claimed depreciation and investment credit for the software…

2Cases cited20 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Petzoldt v. CommissionerUnited States Tax Court · 1989
  3. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  4. Brannen v. CommissionerUnited States Tax Court · 1982
  5. Beck v. CommissionerUnited States Tax Court · 1985

15 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Peat Oil & Gas Assocs. v. CommissionerUnited States Tax Court · 1993
  2. Peat Oil & Gas Assocs. v. CommissionerUnited States Tax Court · 1993

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