Legal Opinion

Red Carpet Car Wash, Inc. v. Commissioner

United States Tax Court

Decided January 10, 1980No. Docket Nos. 4829-77, 4830-77PublishedCited by 4 opinions

Held, Larry Lange Ford, Inc., was the owner of a partnership interest in Rollingwood Apartments, Ltd., in 1973 and 1974, and is entitled to deduct its allocable share of the partnership losses for those years. Held, further, under sec. 1561, I.R.C. 1954, Larry Lange Ford, Inc., is entitled to one-half of the single surtax exemption allowed by sec. 11(d).

1Opinion of the Court

Drennen, Judge:

In these consolidated cases, respondent determined the following deficiencies and additions to tax:

Docket No. Petitioner Year Deficiency Addition to tax under sec. 6651(a), I.R.C. 19541

4829-77 Red Carpet Car Wash, Inc. 1974 $1,684.96 $421.24

4839-77 Larry Lange Ford, Inc. 1973 100,281.26

1974 69,019.48 12,704.87

Petitioner Red Carpet Car Wash, Inc., has conceded the correctness of the respondent’s determinations, thus leaving no issue for determination in docket No. 4829-77. Due to concessions by both parties in docket No. 4830-77, including petitioner Larry Lange Ford, Inc.’s…

2Cases cited11 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
  5. Strong v. CommissionerUnited States Tax Court · 1976

6 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Derr v. CommissionerUnited States Tax Court · 1981
  2. Derr v. CommissionerUnited States Tax Court · 1981
  3. Leuthold v. CommissionerUnited States Tax Court · 1987
  4. Red Carpet Car Wash, Inc. v. CommissionerUnited States Tax Court · 1980

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