Pritchett v. Commissioner
United States Tax Court
Petitioners were limited partners in similar oil and gas drilling partnerships. They made initial cash contributions to their respective partnerships and agreed to make future additional cash contributions if called upon to do so by the general partners in order to satisfy 15 year recourse notes executed by the partnerships in favor of a drilling company.
Read the full summary
Petitioners were limited partners in similar oil and gas drilling partnerships. They made initial cash contributions to their respective partnerships and agreed to make future additional cash contributions if called upon to do so by the general partners in order to satisfy 15 year recourse notes executed by the partnerships in favor of a drilling company. During each year at issue, each partnership incurred a loss, and each petitioner claimed his distributive share of partnership loss in an amount which included both his actual cash contribution to the partnership, as well as his…
1Opinion of the Court
Jacobs, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes:
Docket No. Petitioners Taxable year Deficiency
14586-81 Jerry E. Pritchett and Patricia D. Pritchett 1977 $33,336
18127-81 Donald R. Clifford and Joyce K. Clifford 1977 3,270
18128-81 Alex Indich and Mira Indich 1977 30,492
18477-81 Arthur Knox 1977 7,175
27413-82 Richard J. Buchbinder and Voren L. Buchbinder 1976 11,583
The issue for decision is whether petitioners, as limited partners in five similar limited partnerships engaged in oil and gas drilling operations, are…
2Cases cited7 opinions
- Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
- Brand v. CommissionerUnited States Tax Court · 1983
- Donroy, Ltd., Dostrey, Ltd., Lacancal, Ltd., and Transpat, Ltd. v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Linder v. Vogue Investments, Inc.California Court of Appeal · 1966
- Richard Matthews, Jr., Inc. v. VaughnNevada Supreme Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Levy v. CommissionerUnited States Tax Court · 1988
- Capek v. CommissionerUnited States Tax Court · 1986
- Durkin v. CommissionerUnited States Tax Court · 1986
- Melvin v. CommissionerUnited States Tax Court · 1987
30 more not listed; retrieve them via the Exa API.