122 T.C. No. 17
UNITED STATES TAX COURT
IPO II, A PARTNERSHIP, GERALD R. FORSYTHE, TAX MATTERS PARTNER,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14500-02. Filed April 23, 2004.
IPO II, an LLC but treated as a partnership for
Federal income tax purposes, is owned by IO, an S
corporation, and F, an individual. F owns 100 percent
of the outstanding stock in IO, 70 percent of the
outstanding stock of IE, an S corporation, and 63
percent of the outstanding stock of IP, a C
corporation. F’s daughters own the remaining 30
percent of the outstanding stock of IE.
IPO II purchased an aircraft, and the loan was
guaranteed by F, IE, and IP, but not IO.
R determined that the liability incurred in the
purchase of the aircraft was recourse and fully
allocable to F. P argues that part of the liability
should be allocated to IO because it is related to IE,
a guarantor of the loan.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011