Legal Opinion

Energy Resources Ltd. Partnership v. Commissioner

United States Tax Court

Decided July 13, 1992No. Docket Nos. 20022-87, 15977-88Unpublished

Held: Partnership possessed sufficient incidents of ownership to entitle it to take deductions and credits at issue, if otherwise qualified.

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Held: Partnership possessed sufficient incidents of ownership to entitle it to take deductions and credits at issue, if otherwise qualified. Partnership continued to be engaged in its trade or business and did not retire asset during years at issue; therefore, partnership was entitled to depreciation deductions for years at issue, partnership was permitted to amortize costs over years at issue and thus was not required to take increased amortization in 1983, partnership was entitled to an investment tax credit for 1983, and partnership was not required to recapture during any of the years at…

1Opinion of the Court

ENERGY RESOURCES LIMITED PARTNERSHIP, BAUMGARDNER OIL COMPANY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Energy Resources Ltd. Partnership v. Commissioner

Docket Nos. 20022-87, 15977-881

United States Tax Court

T.C. Memo 1992-386; 1992 Tax Ct. Memo LEXIS 414; 64 T.C.M. (CCH) 80;

July 13, 1992, Filed

Decision will be entered for petitioner.

Held: Partnership possessed sufficient incidents of ownership to entitle it to take deductions and credits at issue, if otherwise qualified. Partnership continued to be engaged in its trade or business and did not retire asset…

2Cases cited26 opinions

  1. Higgins v. CommissionerSupreme Court of the United States · 1941
  2. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  3. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  4. Brannen v. CommissionerUnited States Tax Court · 1982
  5. Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939

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