Davis v. Commissioner
United States Tax Court
Held, under the facts of record, Lewis E. Gaines, individually, and not Gaines Properties, was the general partner in the seven Tennessee and Kentucky limited partnerships.
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Held, under the facts of record, Lewis E. Gaines, individually, and not Gaines Properties, was the general partner in the seven Tennessee and Kentucky limited partnerships. Held, further, the principles of sec. 267(a)(1), I.R.C., 1954, are applicable to sec. 707(b)(1)(B), and therefore, based on Hassen v. Commissioner, 63 T.C. 175 (1974), affd. 599 F.2d 305 (9th Cir. 1979), since the record shows the existence of an agreement between two partnerships owned 100 percent by the same persons and the bank to transfer ownership of certain property from one partnership to the other without the…
1Opinion of the Court
Frank C. Davis, Jr., and Estate of Grace K. Davis, Frank C. Davis, Jr., Executor, Petitioners v. Commissioner of Internal Revenue, Respondent
Davis v. Commissioner
Docket No. 5984-81
United States Tax Court
88 T.C. 122; 1987 U.S. Tax Ct. LEXIS 7; 88 T.C. No. 7;
January 14, 1987. January 14, 1987, Filed
Decision will be entered under Rule 155.
Held, under the facts of record, Lewis E. Gaines, individually, and not Gaines Properties, was the general partner in the seven Tennessee and Kentucky limited partnerships. Held, further, the principles of sec. 267(a)(1), I.R.C., 1954, are applicable to sec.…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Fred M. Archer and Evie B. Archer v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- Davis v. CommissionerUnited States Tax Court · 1987
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