Brannen v. Commissioner
United States Tax Court
Petitioner purchased a 4.95-percent limited partnership interest in early 1974. Thereafter, the general partner, on behalf of the limited partnership, purchased a movie for $ 330,000 cash plus a 4-percent nonrecourse note in the amount of $ 1,400,000, secured only by the movie. The partnership reported large losses during its first 4 years due to the claimed depreciation deductions and the fact that the movie was a box office failure.
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Petitioner purchased a 4.95-percent limited partnership interest in early 1974. Thereafter, the general partner, on behalf of the limited partnership, purchased a movie for $ 330,000 cash plus a 4-percent nonrecourse note in the amount of $ 1,400,000, secured only by the movie. The partnership reported large losses during its first 4 years due to the claimed depreciation deductions and the fact that the movie was a box office failure. Held: The partnership did not have any actual investment in the movie to the extent of the $ 1,400,000 nonrecourse note, as the stated purchase price of the…
1Opinion of the Court
E. A. Brannen and Frances K. Brannen, Petitioners v. Commissioner of Internal Revenue, Respondent
Brannen v. Commissioner
Docket No. 9669-79
United States Tax Court
78 T.C. 471; 1982 U.S. Tax Ct. LEXIS 120; 78 T.C. No. 33;
March 30, 1982, Filed
Decision will be entered under Rule 155.
Petitioner purchased a 4.95-percent limited partnership interest in early 1974. Thereafter, the general partner, on behalf of the limited partnership, purchased a movie for $ 330,000 cash plus a 4-percent nonrecourse note in the amount of $ 1,400,000, secured only by the movie. The partnership reported large losses…
Also in this document: Concurrence.
2Cases cited50 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Crane v. CommissionerSupreme Court of the United States · 1947
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