Fox v. Commissioner
United States Tax Court
Petitioners claimed losses in connection with two partnerships engaged in the acquisition and promotion of books. Held, none of the claimed losses are deductible because the partnerships' activities were not engaged in for profit within the meaning of sec. 183, I.R.C. 1954, and because accrued but unpaid interest on nonrecourse notes given in connection with the purchase of the book publishing rights was not deductible since the notes were too contingent to constitute…
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Petitioners claimed losses in connection with two partnerships engaged in the acquisition and promotion of books. Held, none of the claimed losses are deductible because the partnerships' activities were not engaged in for profit within the meaning of sec. 183, I.R.C. 1954, and because accrued but unpaid interest on nonrecourse notes given in connection with the purchase of the book publishing rights was not deductible since the notes were too contingent to constitute accruable liabilities for tax purposes.
1Opinion of the Court
Nims, Judge-.
In these consolidated cases, respondent determined the following deficiencies in petitioners’ Federal income taxes and additions to tax:
Docket No. Petitioners Addition to tax Year Deficiency sec. 6653(a)2
3593-81 Stuart I. Fox 1976 $1,900.00
1977 1,212.63
3600-81 Gerald J. Roncolato 1976 3,655.00
and Pauline H. Roncolato 1977 2,099.00
5029-81 Michael J. Aranson 1975 1,750.000 $87.50
and Patti J. Aranson 1976 21,482.00 1,074.10
1977 40,433.00 2,022.15
5632-81 Robert S. Markovitz 1975 6,987.00
and Adele B. Markovitz 1976 4,202.00
1977 3,188.00
6169-81 William P. Kratsa 1976 20,667.00
1977…
2Cases cited27 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Brannen v. CommissionerUnited States Tax Court · 1982
- Allen v. CommissionerUnited States Tax Court · 1979
22 more not listed; retrieve them via the Exa API.
3Cited by194 opinions
- Beck v. CommissionerUnited States Tax Court · 1985
- Parker v. CommissionerUnited States Tax Court · 1986
- Rose v. CommissionerUnited States Tax Court · 1987
- Surloff v. CommissionerUnited States Tax Court · 1983
- Abramson v. CommissionerUnited States Tax Court · 1986
189 more not listed; retrieve them via the Exa API.