Legal Opinion

Ferrell v. Commissioner

United States Tax Court

Decided June 16, 1988No. Docket Nos. 8679-86, 8742-86, 7283-87Published

Petitioners purchased limited partnership interests in Western Reserve Oil & Gas Co. (Western Reserve) and claimed deductions for their distributive shares of losses and other deductions reported by Western Reserve for 1981 and 1982. Held, Western Reserve did not incur the disputed losses and expenditures in carrying on a "trade or business" within the meaning of sec. 162(a) or sec. 167(a), I.R.C. 1954; therefore, the claimed deductions are not allowable.

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Petitioners purchased limited partnership interests in Western Reserve Oil & Gas Co. (Western Reserve) and claimed deductions for their distributive shares of losses and other deductions reported by Western Reserve for 1981 and 1982. Held, Western Reserve did not incur the disputed losses and expenditures in carrying on a "trade or business" within the meaning of sec. 162(a) or sec. 167(a), I.R.C. 1954; therefore, the claimed deductions are not allowable. Held, further, the purported obligations on which the interest deductions were allegedly accrued were not genuine indebtedness within the…

1Opinion of the Court

William L. Ferrell, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Ferrell v. Commissioner

Docket Nos. 8679-86, 8742-86, 7283-87

United States Tax Court

90 T.C. 1154; 1988 U.S. Tax Ct. LEXIS 78; 90 T.C. No. 77; 100 Oil & Gas Rep. 375;

June 16, 1988June 16, 1988, Filed

Decisions will be entered under Rule 155.

Petitioners purchased limited partnership interests in Western Reserve Oil & Gas Co. (Western Reserve) and claimed deductions for their distributive shares of losses and other deductions reported by Western Reserve for 1981 and 1982. Held, Western Reserve did not incur…

2Cases cited57 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  3. Dreicer v. CommissionerUnited States Tax Court · 1982
  4. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  5. Brannen v. CommissionerUnited States Tax Court · 1982

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