Dean v. Commissioner
United States Tax Court
Petitioners claimed losses in connection with a limited partnership which obtained all the rights to an original paperback book for a stated amount of $ 877,500 of which $ 742,500 was a nonrecourse note, payable solely from proceeds from these rights and due in 7 years. When obtained by the partnership, estimated receipts from all the rights to the paperback book did not exceed $ 58,500, and the value of such rights was significantly less than that amount.
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Petitioners claimed losses in connection with a limited partnership which obtained all the rights to an original paperback book for a stated amount of $ 877,500 of which $ 742,500 was a nonrecourse note, payable solely from proceeds from these rights and due in 7 years. When obtained by the partnership, estimated receipts from all the rights to the paperback book did not exceed $ 58,500, and the value of such rights was significantly less than that amount. The partnership was syndicated by a brokerage house which controlled it. The amount of the nonrecourse note was determined by a formula…
1Opinion of the Court
Featherston, Judge:
This case was assigned to and heard by Special Trial Judge John J. Pajak, pursuant to the provisions of section 7456(c) of the Code and Rules 180 and 181.1 The Court agrees with and adopts the Special Trial Judge’s opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Pajak, Special Trial Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1976 and 1977 in the amounts of $9,042 and $4,051, respectively. Respondent disallowed the distributable share of losses from a limited partnership, The Season Co., claimed on petitioners’…
2Cases cited24 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
19 more not listed; retrieve them via the Exa API.
3Cited by78 opinions
- Beck v. CommissionerUnited States Tax Court · 1985
- Parker v. CommissionerUnited States Tax Court · 1986
- Rose v. CommissionerUnited States Tax Court · 1987
- Chiu v. CommissionerUnited States Tax Court · 1985
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
73 more not listed; retrieve them via the Exa API.