Colonnade Condominium, Inc. v. Commissioner
United States Tax Court
P, a corporation, held a 50.98-percent majority general partnership interest in GK, a limited partnership. Pursuant to an amendment to the partnership agreement providing for the admission of P's three shareholders, B, F, and M, as additional general partners of GK, P transferred 40.98 percent of its general partnership interest to B, F, and M, who each acquired a 13.66-percent interest in GK.
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P, a corporation, held a 50.98-percent majority general partnership interest in GK, a limited partnership. Pursuant to an amendment to the partnership agreement providing for the admission of P's three shareholders, B, F, and M, as additional general partners of GK, P transferred 40.98 percent of its general partnership interest to B, F, and M, who each acquired a 13.66-percent interest in GK. In exchange for their partnership interests, B, F, and M collectively assumed P's obligation to make annual capital contributions and acquired 40.98 percent of GK's nonrecourse obligations. No…
1Opinion of the Court
Colonnade Condominium, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Colonnade Condominium, Inc. v. Commissioner
Docket No. 323-83
United States Tax Court
91 T.C. 793; 1988 U.S. Tax Ct. LEXIS 133; 91 T.C. No. 51;
October 20, 1988; As amended November 2, 1988; As amended November 3, 1988 October 20, 1988, Filed
Decision will be entered under Rule 155.
P, a corporation, held a 50.98-percent majority general partnership interest in GK, a limited partnership. Pursuant to an amendment to the partnership agreement providing for the admission of P's three shareholders, B, F, and M, as…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Crane v. CommissionerSupreme Court of the United States · 1947
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