taxpayer’s at-risk and basis amounts increased with respect to debt obligations due 10 years subsequent to the taxable years at issue
How later courts described this case
- taxpayer’s at-risk and basis amounts increased with respect to debt obligations due 10 years subsequent to the taxable years at issue
- “[The regulation] factors are not applicable or appropriate for every case. The facts and circumstances of the case in issue remain the primary test.”
- partnership's basis; at risk under sec. 465
Written by the judges who cited it.
The opinion
CLAPP, J., dissenting: I wish to record my dissent with respect to the “At Risk Issue.” I can find no meaningful difference between the facts in this case and those in Pritchett v. Commissioner, 85 T.C. 580 (1985). I would reach the same result as we did in that Court-reviewed opinion.