Durkin v. Commissioner
United States Tax Court
D was a limited partner in B, and G was an indirect limited partner in S. PPC, a producer and distributor of major movies, sold all of its rights, except sequel rights, in six movies to FWC. FWC paid PPC cash and short-term recourse notes equal to 25 percent of the negative cost and long-term nonrecourse notes equal to 75 percent of the negative cost of each movie.
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D was a limited partner in B, and G was an indirect limited partner in S. PPC, a producer and distributor of major movies, sold all of its rights, except sequel rights, in six movies to FWC. FWC paid PPC cash and short-term recourse notes equal to 25 percent of the negative cost and long-term nonrecourse notes equal to 75 percent of the negative cost of each movie. In 1977, on the same day it purchased two of the six movies, FWC sold them to B. In 1978, on the same day it purchased the remaining four of the six movies, FWC sold them to S. B and S paid cash and short-term recourse notes in…
1Opinion of the Court
SIMPSON, Judge:
The Commissioner determined the following deficiencies in, and additions to, the petitioners’ Federal income taxes:
Petitioners Docket Nos. Year Deficiency Addition to tax sec. 6651(a)(1), I.R.C. 1954 1
Thomas J. Durkin and 25313-82 1977 $18,642.56
Colette A. Durkin 18885-82 1978 35,162.50
27623-84 1979 33,376.74
4229-84 1980 17,275.58
Jerome A. Grossman and 22937-83 1978 46,196.00 $10,513
Sybil G. Grossman 17677-84 1979 53,395.00
17602-84 1980 13,802.00 3,450
After concessions by the parties, the issues for decision are: (1) Whether the petitioner, Thomas Durkin, as a limited partner…
2Cases cited68 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
63 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Hulter v. CommissionerUnited States Tax Court · 1988
- Ferrell v. CommissionerUnited States Tax Court · 1988
- Thomas J. Durkin, Colette A. Durkin, Jerome A. Grossman and Sybil G. Grossman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- Marcus W. Melvin and Marilyn E. Melvin v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
- Diamond v. CommissionerUnited States Tax Court · 1989
56 more not listed; retrieve them via the Exa API.