Marriott v. Commissioner
United States Tax Court
Petitioners acquired limited partnership units of a partnership in December of 1972 and April of 1973. Under an amendment to the partnership agreement adopted Dec. 30, 1971, effective for years ending after Dec. 31, 1970, partnership net income and net losses were to be allocated among the limited partners in proportion that the number of units owned by each at the end of the fiscal year bore to the 840 units outstanding.
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Petitioners acquired limited partnership units of a partnership in December of 1972 and April of 1973. Under an amendment to the partnership agreement adopted Dec. 30, 1971, effective for years ending after Dec. 31, 1970, partnership net income and net losses were to be allocated among the limited partners in proportion that the number of units owned by each at the end of the fiscal year bore to the 840 units outstanding. Held, petitioners may deduct only that portion of the losses allocable to the partnership units acquired by them for the period subsequent to the date they acquired those…
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent determined the following income tax deficiencies against the petitioners:
Year Petitioner Deficiency
Harry L. Marriott and Patricia Marriott. $2,268.54 (M o*} r-l
1,791.58 CO Ci i“H
Lester Earl Sutton and Marjory R. Sutton. 398.54 CM rH
741.86 CO t-H
Because of concessions by both petitioners and respondent, the only issue for our decision is whether petitioners may deduct partnership losses allocable to the periods during the taxable years prior to the time petitioners acquired the particular partnership interests, which losses were allocated in accordance with the…
2Cases cited4 opinions
- Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
- Moore v. CommissionerUnited States Tax Court · 1978
- Boynton v. CommissionerUnited States Tax Court · 1979
- Holladay v. CommissionerUnited States Tax Court · 1979
3Cited by22 opinions
- United States v. F. Thomas Little, United States of America v. Peter Chernik, United States of America v. Harold GrutchfieldCourt of Appeals for the Ninth Circuit · 1985
- Elkins v. CommissionerUnited States Tax Court · 1983
- Robert M. Snell and Rosalie J. Snell, Husband and Wife v. United StatesCourt of Appeals for the Eighth Circuit · 1982
- Roccaforte v. CommissionerUnited States Tax Court · 1981
- Richardson v. CommissionerUnited States Tax Court · 1981
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