PRITCHETT v. C.I.R.

Nos. 86-7261 to 86-7263, 86-7265 and 86-7268.

827 F.2d 644 (1987)

JERRY E. PRITCHETT and PATRICIA D. PRITCHETT, et al., PETITIONERS-APPELLANTS, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, RESPONDENT-APPELLEE.

United States Court of Appeals, Ninth Circuit.

Decided September 11, 1987.


Attorney(s) appearing for the Case

Bruce I. Hochman and Martin N. Gelfand, Beverly Hills, Cal., and Marc Marmaro, Los Angeles, Cal. for petitioners-appellants.

Roger M. Olsen and Michael L. Paup, Washington, D.C., for respondent-appellee.

Before KENNEDY, SKOPIL and KOZINSKI, Circuit Judges.


SKOPIL, Circuit Judge:

We must decide in this case whether taxpayers, limited partners in five similar partnerships engaged in oil and gas drilling operations, were "at risk" pursuant to 26 U.S.C. § 465 on certain recourse notes and thus entitled to deduct distributive shares of non-cash partnership losses. The Tax Court in a reviewed, split decision held that each taxpayer was at risk only to the extent of actual cash contribution. Pritchett v. Commissioner...

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