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CANTERBURY HOLDINGS, LLC v. COMMISSIONER OF INTERNAL REVENUE

Nos. 17064-04, 14580-06

T.C. Memo. 2009-175

CANTERBURY HOLDINGS, LLC, CHRISTOPHER B. AND SUSAN L. WOODWARD, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent CANTERBURY HOLDINGS, LLC, CHRISTOPHER B. WOODWARD, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed July 27, 2009.

Attorney(s) appearing for the Case

Charles P. Rettig, Edward M. Robbins, Jr., and David Roth, for petitioners.

Margaret A. Martin, for respondent.

HOLMES, Judge.

Christopher Woodward, David Teece, and Kenneth Klopp were partners in Canterbury Holdings, LLC. Canterbury mounted a takeover of an old New Zealand clothing company in 1999. Its ride turned rough, and the shell company that Canterbury was using had to pony up more money in 2000 and 2001 to make the deal go through. That money actually came from Canterbury itself, but Canterbury argues that these payments are deductible nonetheless. The Commissioner...

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