Wildman v. Commissioner
United States Tax Court
Petitioner was a limited partner in a partnership formed to acquire and distribute a movie. In 1975, the partnership purchased the movie, "Sea Wolf," for $ 460,000 cash plus a nonrecourse note of $ 3,540,000 secured by the movie. The partnership also paid $ 20,000 to the general partners, $ 33,000 in legal fees, and $ 2,500 in promotional expenses.
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Petitioner was a limited partner in a partnership formed to acquire and distribute a movie. In 1975, the partnership purchased the movie, "Sea Wolf," for $ 460,000 cash plus a nonrecourse note of $ 3,540,000 secured by the movie. The partnership also paid $ 20,000 to the general partners, $ 33,000 in legal fees, and $ 2,500 in promotional expenses. The movie was released in December 1975. Held, even though amounts were due in 1975 to the partnership from the movie's exhibition, no depreciation deduction is allowable in 1975 under the income forecast method since the partnership, a cash basis…
1Opinion of the Court
Fay, Judge:
Respondent determined a deficiency of $77,381.90 in petitioners’ 1975 Federal income tax. The issues are whether petitioner Max E. Wildman as a limited partner is entitled to (1) a deduction for a distributive share of losses claimed by the partnership and (2) a claimed investment tax credit arising from the partnership’s purchase and distribution of a movie.1
FINDINGS OF FACT
Some of the facts are stipulated and are found accordingly.
At the time they filed their petition, Max E. Wildman and Joyce L. Wildman resided at Lake Bluff, Ill.
Max E. Wildman (petitioner) is a lawyer who has…
2Cases cited25 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Welch v. HenrySupreme Court of the United States · 1938
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Brannen v. CommissionerUnited States Tax Court · 1982
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3Cited by90 opinions
- Fox v. CommissionerUnited States Tax Court · 1983
- Abramson v. CommissionerUnited States Tax Court · 1986
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Waddell v. CommissionerUnited States Tax Court · 1986
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