Sorrell v. Commissioner
United States Tax Court
Held: With one exception, neither party has satisfied burden of proof with respect to the useful lives of various components of five housing projects, therefore, useful lives assigned in respondent's statutory notice are sustained; held further, investor services fee paid to general partner is a currently deductible expense of the partnership; held further, rent-up fees paid to general partner in 1977 for leases which began in 1978 are amortizable over the life of the leases…
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Held: With one exception, neither party has satisfied burden of proof with respect to the useful lives of various components of five housing projects, therefore, useful lives assigned in respondent's statutory notice are sustained; held further, investor services fee paid to general partner is a currently deductible expense of the partnership; held further, rent-up fees paid to general partner in 1977 for leases which began in 1978 are amortizable over the life of the leases to which the fees pertain, and are in no event deductible in 1977.
1Opinion of the Court
GORDON S. SORRELL, JR., AND JUNE M. SORRELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sorrell v. Commissioner
Docket Nos. 33652-83; 33653-83.1
United States Tax Court
T.C. Memo 1987-351; 1987 Tax Ct. Memo LEXIS 351; 53 T.C.M. (CCH) 1362; T.C.M. (RIA) 87351;
July 21, 1987
Held: With one exception, neither party has satisfied burden of proof with respect to the useful lives of various components of five housing projects, therefore, useful lives assigned in respondent's statutory notice are sustained; held further, investor services fee paid to general partner is a currently…
2Cases cited33 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
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- Julie A. Toth v. CommissionerUnited States Tax Court · 2007
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