Larson v. Commissioner
United States Tax Court
Petitioners owned limited partnership interests in two real estate syndications organized under the California Uniform Limited Partnership Act. The sole general partner in each partnership was a corporation, independent of the limited partners, organized for the purpose of promoting and managing such syndications. Under State law, the partnerships would be dissolved by the bankruptcy of the general partner.
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Petitioners owned limited partnership interests in two real estate syndications organized under the California Uniform Limited Partnership Act. The sole general partner in each partnership was a corporation, independent of the limited partners, organized for the purpose of promoting and managing such syndications. Under State law, the partnerships would be dissolved by the bankruptcy of the general partner. The general partner invested no funds in the partnerships and its interests were subordinated to those of the limited partners. The limited partners had the right to vote to remove the…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in Federal income tax as follows:
Taxable Docket No. Petitioner year Deficiency
5530-72 Phillip G. Larson_ 1968 $6,744
5266-73 American Precision Metals- 1969 3,703
1970 1,810
5267-73 Phillip G. Larson_ 1966 1,409
1969 5,943
1970 6,389
Other issues having been disposed of by mutual agreement of the parties, the sole issue remaining for decision is whether the limited partnerships involved in this proceeding constitute associations taxable as corporations within the meaning of section 7701(a)(3).2
An opinion was filed in this case on October 21,…
2Cases cited12 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Helvering v. CombsSupreme Court of the United States · 1935
- Bolger v. CommissionerUnited States Tax Court · 1973
- Estate of Craig M. Smith, Deceased, Ruth E. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Diamond v. CommissionerUnited States Tax Court · 1971
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3Cited by20 opinions
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- New Hampshire Resident Ltd. Partners v. New Hampshire Department of Revenue AdministrationSupreme Court of New Hampshire · 2011
- Xilinx Inc. v. Comm'rUnited States Tax Court · 2005
- CSX Corp. v. CommissionerUnited States Tax Court · 1987
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