Clayden v. Commissioner
United States Tax Court
Ps executed purchase agreements for the alleged purpose to acquire videotapes for use in commercial television. The purchase agreements were structured to allow Ps an investment credit in such an amount to recover income taxes paid in previous years. Ps also entered into distribution agreements for the alleged purpose to distribute, promote, and advertise the videotapes.
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Ps executed purchase agreements for the alleged purpose to acquire videotapes for use in commercial television. The purchase agreements were structured to allow Ps an investment credit in such an amount to recover income taxes paid in previous years. Ps also entered into distribution agreements for the alleged purpose to distribute, promote, and advertise the videotapes. The distribution agreement was structured to allow Ps to reduce their current year's income tax liabilities to zero. Although cash downpayments were due on the agreements, promissory notes were used in lieu of the cash…
1Opinion of the Court
OPINION
FEATHERSTON, Judge:
These consolidated cases were assigned to Special Trial Judge Marvin F. Peterson pursuant to section 7456(d)2 (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755), and Rules 180, 181, and 183.3 The Court agrees with and adopts his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PETERSON, Special Trial Judge:
These consolidated cases were selected by the parties and approved by the Court to serve as test cases for resolving issues common to a larger group of taxpayers who invested during the…
2Cases cited6 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Rose v. CommissionerUnited States Tax Court · 1987
- Patin v. CommissionerUnited States Tax Court · 1987
- Cherin v. CommissionerUnited States Tax Court · 1987
- Zirker v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Rybak v. CommissionerUnited States Tax Court · 1988
- Costa v. CommissionerUnited States Tax Court · 1990
- River City Ranches 1 Ltd. v. Comm'rUnited States Tax Court · 2007
- Beam v. CommissionerUnited States Tax Court · 1990
- AidooUnited States Tax Court · 1993
10 more not listed; retrieve them via the Exa API.