Legal Opinion

Falkoff v. Commissioner

United States Tax Court

Decided May 15, 1974No. Docket No. 2087-71Published

During 1966 petitioner was a partner in Empire, which in turn held a 22 1/2-percent limited partnership interest in Venture. From March of 1962 until June of 1966, the only other partner in Venture was ODE, a subsidiary of Interstate. On or about June 2, 1966, a group of investors acquired a portion of ODE's partnership interest in Venture and loaned Venture $ 3,500,000. None of the partners in Venture incurred any personal liability as a result of the loans.

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During 1966 petitioner was a partner in Empire, which in turn held a 22 1/2-percent limited partnership interest in Venture. From March of 1962 until June of 1966, the only other partner in Venture was ODE, a subsidiary of Interstate. On or about June 2, 1966, a group of investors acquired a portion of ODE's partnership interest in Venture and loaned Venture $ 3,500,000. None of the partners in Venture incurred any personal liability as a result of the loans. Venture distributed $ 274,275 to Empire. At about the same time, Empire received a loan of $ 500,000 from Jupiter, the parent…

1Opinion of the Court

Milton Falkoff and Jeannette L. Falkoff, Petitioners v. Commissioner of Internal Revenue, Respondent

Falkoff v. Commissioner

Docket No. 2087-71

United States Tax Court

62 T.C. 200; 1974 U.S. Tax Ct. LEXIS 108; 62 T.C. No. 22;

May 15, 1974, Filed

Decision will be entered under Rule 155.

During 1966 petitioner was a partner in Empire, which in turn held a 22 1/2-percent limited partnership interest in Venture. From March of 1962 until June of 1966, the only other partner in Venture was ODE, a subsidiary of Interstate. On or about June 2, 1966, a group of investors acquired a portion of ODE's…

2Cases cited7 opinions

  1. Mayerson v. CommissionerUnited States Tax Court · 1966
  2. Stilwell v. CommissionerUnited States Tax Court · 1966
  3. Arlen v. Comm'rUnited States Tax Court · 1967
  4. Falkoff v. CommissionerUnited States Tax Court · 1974
  5. The Estate of Robert B. Dupree, Robert P. Dupree, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1968

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