Resnik v. Commissioner
United States Tax Court
A limited partnership, of which petitioner-husband was a limited partner, on the beginning and ending day of its initial taxable year (being a 1-day taxable year) prepaid interest for 4 years and 3 months hence. The partnership reported no income and no other deductions for such 1-day taxable year.
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A limited partnership, of which petitioner-husband was a limited partner, on the beginning and ending day of its initial taxable year (being a 1-day taxable year) prepaid interest for 4 years and 3 months hence. The partnership reported no income and no other deductions for such 1-day taxable year. Petitioner-husband's share of the partnership loss created by the prepaid interest deduction was claimed by petitioners on their joint return which the Commissioner disallowed under sec. 446(b), I.R.C. 1954, on the grounds that the prepaid interest deduction materially distorted the income of the…
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined a deficiency in the Federal income tax of petitioners for the taxable year 1969 in the amount of $15,135.30. The sole issue for decision is whether petitioners are entitled to deduct their claimed distributive share of a partnership loss produced by the prepayment of interest by the partnership for a period in excess of 4 years.
All of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein and adopted as our findings. The case has been submitted under Rule 122 of the Tax Court’s Rules of…
2Cases cited26 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. HansenSupreme Court of the United States · 1959
- United States v. BasyeSupreme Court of the United States · 1973
- Heiner v. MellonSupreme Court of the United States · 1938
- Sandor v. CommissionerUnited States Tax Court · 1974
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3Cited by68 opinions
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
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- Ewing v. CommissionerUnited States Tax Court · 1988
- Seligman v. CommissionerUnited States Tax Court · 1985
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