Marine v. Commissioner
United States Tax Court
S, the promoter and general partner of numerous limited partnerships, represented that limited partners in S partnerships would be entitled to claim first-year interest deductions in an amount equal to their cash contributions. P-husband and Ps' trust acquired interests in two S limited partnerships. The first-year interest deductions were based on circular transfers of funds, rather than loans, and no interest was paid.
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S, the promoter and general partner of numerous limited partnerships, represented that limited partners in S partnerships would be entitled to claim first-year interest deductions in an amount equal to their cash contributions. P-husband and Ps' trust acquired interests in two S limited partnerships. The first-year interest deductions were based on circular transfers of funds, rather than loans, and no interest was paid. By nonrecourse financing, each limited partnership acquired legal title to certain real estate at prices controlled by S and substantially in excess of the sellers'…
1Opinion of the Court
Cohen, Judge:
Respondent determined deficiencies of $29,851.66, $22,034, $9,215.95, and $9,578 in petitioners’ Federal income tax for 1979, 1980, 1981, and 1982, respectively, and an addition to tax under section 6661 of $957.80 for 1982. The issues for decision are (1) whether petitioners have deductible theft losses on their initial cash contributions to certain limited partnerships; (2) whether petitioners are entitled to claim losses in connection with the real estate activities of the limited partnerships; and (3) whether petitioners are hable for additions to tax under sections 6653(a)…
2Cases cited65 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Dreicer v. CommissionerUnited States Tax Court · 1982
- United States v. CartwrightSupreme Court of the United States · 1973
60 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Chao v. CommissionerUnited States Tax Court · 1989
- Rogers v. CommissionerUnited States Tax Court · 1990
- Rod Warren Ink v. CommissionerUnited States Tax Court · 1989
- Bukove v. CommissionerUnited States Tax Court · 1989
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