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HGA CINEMA TRUST v. C.I.R.

No. 90-2101.

950 F.2d 1357 (1991)

HGA CINEMA TRUST, Burton W. Kanter, Trustee, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 27, 1991.

Attorney(s) appearing for the Case

Burton W. Kanter (argued), Neal, Gerber & Eisenberg, Chicago, Ill., for petitioner-appellant.

Abraham N.M. Shashy, Jr., I.R.S., Gary R. Allen, David I. Pincus, Joan I. Oppenheimer (argued), Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, D.C., for respondent-appellee.

Before BAUER, Chief Judge, and COFFEY and MANION, Circuit Judges.

BAUER, Chief Judge.

In this appeal, we must decide whether a partnership's long-term promissory notes represent valid debt. The United States Tax Court held that these notes were not valid indebtedness. We affirm.

I.

The pertinent facts of this case have been set forth ably by the United States Tax Court. See HGA Cinema Trust, Burton Kanter, Trustee v. Commissioner of Internal Revenue, 57 T.C.M. (CCH) 1066

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