Markin v. Commissioner
United States Tax Court
Ps claimed deductions and investment tax credits in connection with a motion picture through their interests as limited partners in a partnership. Ps move the Court to vacate a stipulation of fact pursuant to Rule 91(e), Tax Court Rules of Practice and Procedure, on the ground of mutual mistake of fact. Held, Ps' motion for relief under Rule 91(e), Tax Court Rules of Practice and Procedure, is denied.
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Ps claimed deductions and investment tax credits in connection with a motion picture through their interests as limited partners in a partnership. Ps move the Court to vacate a stipulation of fact pursuant to Rule 91(e), Tax Court Rules of Practice and Procedure, on the ground of mutual mistake of fact. Held, Ps' motion for relief under Rule 91(e), Tax Court Rules of Practice and Procedure, is denied. Held further, the partnership did not acquire a depreciable interest in the motion picture but purchased an intangible contract right to payments contingent on the success of the motion picture.…
1Opinion of the Court
DAVID MARKIN AND BARBARA C. MARKIN, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Markin v. Commissioner
Docket Nos. 18245-86; 19805-86; 27384-86
United States Tax Court
T.C. Memo 1989-665; 1989 Tax Ct. Memo LEXIS 665; 58 T.C.M. (CCH) 994; T.C.M. (RIA) 89665;
December 21, 1989
Ps claimed deductions and investment tax credits in connection with a motion picture through their interests as limited partners in a partnership. Ps move the Court to vacate a stipulation of fact pursuant to Rule 91(e), Tax Court Rules of Practice and Procedure, on the ground of mutual mistake of fact.
2Cases cited14 opinions
- United States v. PhellisSupreme Court of the United States · 1921
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Zirker v. CommissionerUnited States Tax Court · 1986
- Hilton v. CommissionerUnited States Tax Court · 1980
- Carol W. Hilton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
9 more not listed; retrieve them via the Exa API.
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- Bankamerica Corp. v. CommissionerUnited States Tax Court · 1997