Derr v. Commissioner
United States Tax Court
In early 1973, A decided to syndicate the X limited partnership which would purchase and operate a certain apartment complex. To this end, A published a prospectus offering the sale of X partnership units to Illinois residents. The prospectus promised substantial tax benefits in 1973 from an investment in X and indicated that A's wholly owned corporation, Z, had already contracted to purchase the apartment complex.
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In early 1973, A decided to syndicate the X limited partnership which would purchase and operate a certain apartment complex. To this end, A published a prospectus offering the sale of X partnership units to Illinois residents. The prospectus promised substantial tax benefits in 1973 from an investment in X and indicated that A's wholly owned corporation, Z, had already contracted to purchase the apartment complex. Nevertheless, Z had not contracted to purchase the apartment before the publication of the prospectus. On June 30, 1973, Z executed the purchase agreement for the apartment…
1Opinion of the Court
Wiles, Judge:
Respondent determined a $6,184.80 deficiency in petitioners’ 1973 Federal income tax. After a concession by respondent, the sole issue for decision is whether petitioner William O. Derr, a limited partner in the Aragon Apartments partnership, is entitled to deduct his distributive share of the partnership loss for 1973. The resolution of this issue turns on whether the partnership is entitled to various deductions in connection with the ownership and operation of an apartment complex in 1973.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
William…
2Cases cited58 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
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3Cited by57 opinions
- Siegel v. CommissionerUnited States Tax Court · 1982
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