Larson v. Commissioner
United States Tax Court
Petitioners owned limited partnership interests in two real estate syndications organized under the California Uniform Limited Partnership Act. The sole general partner in each partnership was a corporation, independent of the limited partners, organized for the purpose of promoting and managing such syndications. Under State law, the partnerships would be dissolved by the bankruptcy of the general partner.
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Petitioners owned limited partnership interests in two real estate syndications organized under the California Uniform Limited Partnership Act. The sole general partner in each partnership was a corporation, independent of the limited partners, organized for the purpose of promoting and managing such syndications. Under State law, the partnerships would be dissolved by the bankruptcy of the general partner. The general partner invested no funds in the partnerships and its interests were subordinated to those of the limited partners. The limited partners had the right to vote to remove the…
1Opinion of the Court
Phillip G. Larson, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Larson v. Commissioner
Docket Nos. 5530-72, 5266-73, 5267-73
United States Tax Court
66 T.C. 159; 1976 U.S. Tax Ct. LEXIS 118;
April 27, 1976, Filed
Decisions will be entered under Rule 155.
Petitioners owned limited partnership interests in two real estate syndications organized under the California Uniform Limited Partnership Act. The sole general partner in each partnership was a corporation, independent of the limited partners, organized for the purpose of promoting and managing such syndications. Under…
Also in this document: Concurrence · Dawson; Concurrence · Goffe; Dissent · Raum; Dissent · Drennen; Dissent · Scott; Dissent · Simpson; Dissent · Quealy.
2Cases cited69 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Meinhard v. SalmonNew York Court of Appeals · 1928
- United States v. MenascheSupreme Court of the United States · 1955
- Commissioner v. TowerSupreme Court of the United States · 1946
- Helvering v. HallockSupreme Court of the United States · 1940
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