Seaman v. Commissioner
United States Tax Court
Petitioners deducted their distributive shares of the losses claimed during the years in question by the Knox County Partners, Ltd., a limited partnership organized and operated for the avowed purpose of exploiting certain coal rights. The partnership's loss for 1976 was attributable to deductions for advanced royalties, which the partnership "paid" in the form of cash and a nonrecourse note.
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Petitioners deducted their distributive shares of the losses claimed during the years in question by the Knox County Partners, Ltd., a limited partnership organized and operated for the avowed purpose of exploiting certain coal rights. The partnership's loss for 1976 was attributable to deductions for advanced royalties, which the partnership "paid" in the form of cash and a nonrecourse note. Respondent disallowed petitioners' distributive shares of the partnership's loss for 1976. Respondent also disallowed certain of petitioners' distributive shares of the partnership's loss for 1977…
1Opinion of the Court
Sterrett, Judge:
Respondent issued statutory notices of deficiency in these consolidated cases that determined deficiencies in petitioners’ Federal income taxes as follows:
Docket No. Petitioner Year Deficiency
1235-81 John W. Seaman, Jr., 1976 $43,451.00
and Bettye H. Seaman 1977 3,342.98
1236-81 Bruce A. Samson 1976 130,035.80
and Adajean L. Samson 1977 7,874.98
1237-81 Harold G. Nix 1976 43,343.00
1977 2,624.16
1238-81 Richard F. Lockey 1976 29,682.70 and Anne S. Lockey
Docket No. Petitioner Year Deficiency
1239-81 William J. Schifino and Lois A. Schifino 1976 $28,062.70
1596-81 Edward Hoornstra and…
2Cases cited32 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dreicer v. CommissionerUnited States Tax Court · 1982
- United States v. SullivanSupreme Court of the United States · 1927
- Golanty v. CommissionerUnited States Tax Court · 1979
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
27 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- James P. Thomas and Mary Lou Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1986
- Thomas v. CommissionerUnited States Tax Court · 1985
- Capek v. CommissionerUnited States Tax Court · 1986
- Portland Golf Club v. CommissionerSupreme Court of the United States · 1990
- West v. CommissionerUnited States Tax Court · 1987
43 more not listed; retrieve them via the Exa API.