Legal Opinion
S. Peter Lebowitz and Theresa Lebowitz v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided November 1, 1990No. 1021, Docket 89-4144PublishedCited by 9 opinions
1Opinion of the Court
OAKES, Chief Judge:
This tax appeal, involving the proper income tax treatment of a nonrecourse note, is from a decision of the United States Tax Court, Mary Ann Cohen, Judge, entered on June 21, 1989 and unofficially reported at 57 T.C.M. (CCH) 179 (1989), adopting the opinion of the Special Trial Judge, Hu S. Vandervort.
In December 1976, taxpayer S. Peter Lebowitz became a limited partner in the coal mining partnership of Fenwick Associates (“Fenwick”). Fenwick, which operates under the accrual method of accounting on a calendar-year basis, was formed as a New York limited partnership to…
2Cases cited32 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Crane v. CommissionerSupreme Court of the United States · 1947
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
27 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Howard I. Lukens v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Rogers v. United StatesDistrict Court, D. Kansas · 1999
- Regents Park PartnersUnited States Tax Court · 1992
- Bailey v. CommissionerUnited States Tax Court · 1992
4 more not listed; retrieve them via the Exa API.