Hagler v. Commissioner
United States Tax Court
Petitioners invested in a partnership that acquired a license to enhance and sell a computer program for the preparation of income tax returns. The partnership entered into a research and development agreement with a corporation under which the enhancements to the computer program were to be made.
Read the full summary
Petitioners invested in a partnership that acquired a license to enhance and sell a computer program for the preparation of income tax returns. The partnership entered into a research and development agreement with a corporation under which the enhancements to the computer program were to be made. Held: A $ 1,200,000 nonrecourse promissory note issued by the partnership in connection with the license of the computer program was illusory on the day it was signed, Dec. 31, 1976. The promissory note is therefore subject to the at-risk rule of sec. 704(d), I.R.C. 1954 (the predecessor to sec.…
1Opinion of the Court
SWIFT, Judge:
In timely statutory notices of deficiency, respondent determined deficiencies in petitioners’ Federal income tax liabilities as follows:
Petitioners Years Deficiencies
Joel Hagler and 1977 $2,621.00
Irene Hagler 1978 4,624.00
Frederick M. Dahlmeier and Jane G. Dahlmeier 1977 18,273.62 1978 12,251.40 1979 6,968.96
Thomas C. Mullen and Joann Mullen 1977 15,330.66 1978 12,760.56 1979 8,648.16
These cases were consolidated by order of the Court dated March 23, 1983. The Federal income tax deficiencies in dispute herein relate to partnership losses arising from petitioners’ investments in a…
2Cases cited29 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
24 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Gershkowitz v. CommissionerUnited States Tax Court · 1987
- Farmer v. CommissionerUnited States Tax Court · 1994
- Leger v. CommissionerUnited States Tax Court · 1987
- Green v. CommissionerUnited States Tax Court · 1989
14 more not listed; retrieve them via the Exa API.