Legal Opinion
Hamilton v. United States
United States Court of Claims
Decided August 25, 1982No. 460-79T; No. 461-79T; No. 179-80TPublishedCited by 19 opinions
1Opinion of the CourtSmith, Judge
Plaintiffs claim income tax refunds for 1969 on grounds that the Internal Revenue Service (Service) improperly interpreted the partnership agreements of certain partnerships1 of which Ferris and Frederic Hamilton2 were the general partners. Defendant contends that certain allocation provisions in the agreements created nonrecourse loans to plaintiffs from the limited partners of each of the partnerships in question. Defendant contends further that the allocation provisions of the partnership agreements lack economic substance apart from their tax consequences and should not be recognized.…
2Cases cited11 opinions
- United States v. BasyeSupreme Court of the United States · 1973
- Kirby Petroleum Co. v. CommissionerSupreme Court of the United States · 1946
- United States v. Henry Prentiss & Co.Supreme Court of the United States · 1933
- Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
- Orrisch v. CommissionerUnited States Tax Court · 1970
6 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Elrod v. CommissionerUnited States Tax Court · 1986
- Goldfine v. CommissionerUnited States Tax Court · 1983
- James E. And Frances J. Allison v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Mary K.S. Ogden v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
14 more not listed; retrieve them via the Exa API.