109 T.C. No. 13
UNITED STATES TAX COURT
ROBERT L. WHITMIRE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21849-84. Filed October 29, 1997.
Held: Notwithstanding the recourse nature of a
third-party bank loan, due to various loss-limiting
features associated with a computer equipment leasing
transaction, petitioner is not to be regarded as at
risk under sec. 465, I.R.C., with regard to related
partnership debt obligations.
Stephen D. Gardner, for petitioner.
Elizabeth P. Flores, Martin L. Shindler, Marcie B. Harrison,
Brian J. Condon, Victoria J. Kanrek, and David A. Williams, for
respondent.
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