HOLLANDER v. COMMISSIONER

Docket No. 19678-85, 36125-86.

57 T.C.M. 96 (1989)

T.C. Memo. 1989-163

Bentley A. Hollander and Clara B. Hollander v. Commissioner.

United States Tax Court.

Filed April 13, 1989.


Attorney(s) appearing for the Case

David A. Schmudde, 535 5th Ave., New York, N.Y., and Martin M. Shenkman, 1375 Broadway, New York, N.Y., for the petitioners. Frank Agostino, C. Ellen Pilsecker, Matthew Magnone, and Patrick E. Whelan, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1980 and 1981 in the amounts of $31,232.25 and $43,091, respectively. The issues for decision are: 1) whether the motion picture partnership "Hearts Associates" transaction lacked economic substance; 2) whether the partnership purchased the motion picture "Second Hand Hearts;" 3) whether the partnership can include...

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