Doctors Hosp. Real Estate v. Commissioner
United States Tax Court
In 1979, a group of doctors organized a corporation, C, to develop and operate a hospital. C's shareholders formed a limited partnership, D, comprised of 43 partners, all but 2 of which were shareholders of C. C leased certain land to D and D agreed to lease to C certain fixed equipment and a hospital building to be constructed on the land.
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In 1979, a group of doctors organized a corporation, C, to develop and operate a hospital. C's shareholders formed a limited partnership, D, comprised of 43 partners, all but 2 of which were shareholders of C. C leased certain land to D and D agreed to lease to C certain fixed equipment and a hospital building to be constructed on the land. D did not manufacture or produce the equipment subject to the lease to C. Under the lease from D to C, D's maximum contributions for expenses related to the fixed equipment totaled $ 550,000. Under the lease, the rent C owed D was the amount necessary to…
1Opinion of the Court
DOCTORS HOSPITAL REAL ESTATE, LTD., DOCTORS HOSPITAL MANAGEMENT CO., INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Doctors Hosp. Real Estate v. Commissioner
Docket No. 20343-91
United States Tax Court
T.C. Memo 1994-143; 1994 Tax Ct. Memo LEXIS 144; 67 T.C.M. (CCH) 2591;
March 31, 1994, Filed
Decision will be entered under Rule 155.
In 1979, a group of doctors organized a corporation, C, to develop and operate a hospital. C's shareholders formed a limited partnership, D, comprised of 43 partners, all but 2 of which were shareholders of C. C leased certain land…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Barbados 6, Ltd. v. CommissionerUnited States Tax Court · 1985
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Alex A. Aboussie, Alice Aboussie, Robert Aboussie and Linda Aboussie v. United StatesCourt of Appeals for the Eighth Circuit · 1985
- Carlson v. CommissionerUnited States Tax Court · 1982
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