Legal Opinion

George v. Commissioner

Court of Appeals for the Fifth Circuit

Decided October 24, 1986No. 85-4786PublishedCited by 3 opinions

1Opinion of the Court

THORNBERRY, Circuit Judge:

Taxpayers were limited partners in the Biloxi Hotel Properties Partnership (“BHPP”) and claimed their distributive share of losses from the development of the Biloxi Hilton Hotel. That project included both a hotel and a golf course. The Commissioner disallowed those losses because two corporations, Argo Hotels, Inc. (“Argo”) and Coastal Golf, Inc. (“CG”), owned the project during the pertinent period. The Tax Court disagreed with the Commissioner in part: it found that Argo acted as agent for BHPP with respect to the hotel, but that neither Argo nor CG acted as an…

2Cases cited10 opinions

  1. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  2. Harrison Property Management Co. v. United StatesUnited States Court of Claims · 1973
  3. Benjamin Raphan and Myrna Raphan v. The United StatesCourt of Appeals for the Federal Circuit · 1985
  4. Roccaforte v. CommissionerUnited States Tax Court · 1981
  5. Joseph A. Roccaforte, Jr. And Sandra F. Roccaforte, Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1983

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3Cited by3 opinions

  1. Commissioner v. BollingerSupreme Court of the United States · 1988
  2. George v. CommissionerCourt of Appeals for the Fifth Circuit · 1988
  3. George v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986

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