Whitmire v. Commissioner
United States Tax Court
HELD: Notwithstanding the recourse nature of a third-party bank loan, due to various loss-limiting features associated with a computer equipment leasing transaction, petitioner is not to be regarded as at risk under sec. 465, I.R.C., with regard to related partnership debt obligations.
1Opinion of the Court
ROBERT L. WHITMIRE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Whitmire v. Commissioner
Tax Ct. Dkt. No. 21849-84
United States Tax Court
109 T.C. 266; 1997 U.S. Tax Ct. LEXIS 65; 109 T.C. No. 13;
October 29, 1997, Filed
HELD: Notwithstanding the recourse nature of a third-party bank loan, due to various loss-limiting features associated with a computer equipment leasing transaction, petitioner is not to be regarded as at risk under sec. 465, I.R.C., with regard to related partnership debt obligations.
Elizabeth P. Flores, Martin L. Shindler, Marcie B. Harrison, Brian J. Condon,…
2Cases cited20 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Levy v. CommissionerUnited States Tax Court · 1988
- Larsen v. CommissionerUnited States Tax Court · 1987
- Capek v. CommissionerUnited States Tax Court · 1986
15 more not listed; retrieve them via the Exa API.