Legal Opinion
Georgetowne Sound v. United States
District Court, D. Maryland
Decided May 4, 1993No. Civ. Y-91-3104PublishedCited by 1 opinion
1Opinion of the Court
MEMORANDUM
JOSEPH H. YOUNG, Senior District Judge.
George Christian, Jr. (Petitioner), appearing pro se, challenges the Government’s 1983-1984 Final Partnership Administrative Adjustment (FPAA) for an investment made by Petitioner’s business and bears the burden of showing that the Government’s determinations were erroneous. Welch v. Helvering, 290 U.S. 111, 54 S.Ct. 8, 78 L.Ed. 212 (1933). Since Petitioners were motivated solely by tax benefits and the transaction offered no reasonable possibility of profit, the Government properly disallowed all losses, deductions, expenses, and tax credits…
2Cases cited5 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- C.D. Hunt, Jr. v. Commissioner of Internal Revenue, Jackie Robinson Carolyn K. Robinson v. Commissioner of Internal Revenue, Christine M. Powell v. Commissioner of Internal Revenue, Larry T. Suitt Gwendolyn C. Suitt v. Commissioner of Internal Revenue, Wilbert Joseph Hamilton Geneva A. Hamilton v. Commissioner of Internal Revenue, Alfonzo Hamilton, Jr. Beatrice G. Hamilton v. Commissioner of Internal Revenue, David Reid, III Gloria J. Reid v. Commissioner of Internal Revenue, Lee Johnson, Jr. Veronica B. Johnson v. Commissioner of Internal Revenue, Ronald Eric Johnson Rosetta B. Johnson v. Commissioner of Internal Revenue, Exter G. Gilmore, Jr. Olivia G. Gilmore v. Commissioner of Internal Revenue, Ronald Daye Bobbie Daye v. Commissioner of Internal Revenue, Ronald Daye Bobbie Daye v. Commissioner of Internal Revenue, Thelma B. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1991
3Cited by1 opinion
- Christian v. CommissionerDistrict Court, D. Maryland · 1999