Crescent Holdings, LLC v. Comm'r
United States Tax Court
Holdings was a limited liability company formed on Sept. 7, 2006, and classified as a partnership for Federal income tax purposes.
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Holdings was a limited liability company formed on Sept. 7, 2006, and classified as a partnership for Federal income tax purposes. Resources was a limited liability company whose ownership was transferred to Holdings on Sept. 7, 2006. On Sept. 7, 2006, Resources entered into an employment agreement with P to have Holdings transfer a 2% interest in Holdings to P if P served as chief executive officer (CEO) of Resources for a period of three years ending on Sept. 7, 2009. The 2% interest was subject to a substantial risk of forfeiture and was not transferable. Holdings allocated partnership…
1Opinion of the Court
CRESCENT HOLDINGS, LLC, ARTHUR W. FIELDS AND JOLEEN H. FIELDS, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Crescent Holdings, LLC v. Comm'r
Docket Nos. 23756-11, 23757-11.
United States Tax Court
141 T.C. 477; 2013 U.S. Tax Ct. LEXIS 35; 141 T.C. No. 15;
December 2, 2013, Filed
Crescent Res. Litig. Trust v. Fields (In re Crescent Res., LLC), 2012 Bankr. LEXIS 843 (Bankr. W.D. Tex., Mar. 2, 2012)Crescent Res. Litig. Trust v. Duke Energy Corp., 500 B.R. 464, 2013 U.S. Dist. LEXIS 143726 (W.D. Tex., Oct. 4, 2013)
Holdings was a limited…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. BlissSupreme Court of the United States · 1934
- Blonien v. Comm'rUnited States Tax Court · 2002
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
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