Edward T. And Billie R. Pratt, William D. And Anita Pratt, Jack E. And Crystal A. Pratt v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• management fees paid according to percent of rentals held not a § 707(c) payment but share of profits
• “since there is no dispute in this case that the taxpayers’ loans to their partnerships were bona fide loans, the loan transactions are to be treated under § 1.707-1(a) of the Treasury Regulations, as coming within the provisions of § 707(a

Source: CourtListener parenthetical corpus (CC0).