Fife v. Commissioner
United States Tax Court
Petitioners were limited partners in a partnership formed to acquire and distribute a motion picture film. In 1973, the partnership purchased the American and Canadian rights to distribute the picture for $ 75,000 cash, a negotiable promissory note of $ 90,000, and a nonrecourse note of $ 1,335,000 payable only out of the proceeds derived from the distribution of the film. The picture had been exhibited extensively in Europe prior to the purchase by the partnership.
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Petitioners were limited partners in a partnership formed to acquire and distribute a motion picture film. In 1973, the partnership purchased the American and Canadian rights to distribute the picture for $ 75,000 cash, a negotiable promissory note of $ 90,000, and a nonrecourse note of $ 1,335,000 payable only out of the proceeds derived from the distribution of the film. The picture had been exhibited extensively in Europe prior to the purchase by the partnership. The partnership claimed an investment tax credit on the picture and elected to compute depreciation on the picture by use of the…
1Opinion of the Court
OPINION
Sterrett, Judge:
These six consolidated cases are before the Court on respondent’s motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The issues for decision raised by the motion are (1) whether Jupiter Associates is entitled to depreciation deductions for the taxable years in question under the income forecast method; and (2) in two of the cases (docket Nos. 3Í50-80 and 3154-80), whether the Jupiter Associates partners are entitled to claim an investment tax credit on a motion picture film that was exhibited in Europe prior to its…
2Cases cited15 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Welch v. HenrySupreme Court of the United States · 1938
10 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Durkin v. CommissionerUnited States Tax Court · 1986
- Horace Lynn Wiggins and Jimmie Sue Wiggins v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Bailey v. CommissionerUnited States Tax Court · 1988
- Goodson-Todman Enterprises, Ltd. v. CommissionerUnited States Tax Court · 1985
- Reinberg v. CommissionerUnited States Tax Court · 1988
25 more not listed; retrieve them via the Exa API.