Legal Opinion

Whitmire v. Commissioner

United States Tax Court

Decided October 29, 1997No. Tax Ct. Dkt. No. 21849-84Published

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

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  3. Levy v. CommissionerUnited States Tax Court · 1988
  4. Larsen v. CommissionerUnited States Tax Court · 1987
  5. Capek v. CommissionerUnited States Tax Court · 1986

15 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API