Saba P'ship v. Comm'r
United States Tax Court
During 1990 and 1991, B, a domestic corporation, realized substantial capital gains from the sale of a number of its business units.
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During 1990 and 1991, B, a domestic corporation, realized substantial capital gains from the sale of a number of its business units. In 1990, B joined with a foreign bank (ABN) purportedly to form two general partnerships, S and O. The partnerships engaged in financial transactions that were intended to satisfy the requirements of a contingent installment sale under I.R.C. sec. 453. Relying on the ratable basis recovery rules under sec. 15A.453-1(c), Temporary Income Tax Regs., 46 Fed. Reg. 10709 (Feb. 4, 1981), the transactions were prearranged so that a substantial percentage of the…
1Opinion of the Court
SABA PARTNERSHIP, BRUNSWICK CORPORATION, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent OTRABANDA INVESTERINGS PARTNERSHIP, BRUNSWICK CORPORATION, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Saba P'ship v. Comm'r
No. 1470-97; No. 1471-97
United States Tax Court
T.C. Memo 2003-31; 2003 Tax Ct. Memo LEXIS 31; 85 T.C.M. (CCH) 817; T.C.M. (RIA) 55035;
February 11, 2003, Filed
Partnerships were not organized or operated for nontax business purpose. Partnerships disregarded for federal income tax purposes.
During 1990 and 1991, B, a…
2Cases cited13 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Knetsch v. United StatesSupreme Court of the United States · 1960
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
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3Cited by4 opinions
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- Bank of New York Mellon Corporation, as Successor in Interest to The Bank of New York Company, Inc. v. CommissionerUnited States Tax Court · 2013