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Bussing v. Commissioner

United States Tax Court
88 T.C. 449 (1987)

Written by Heather Whittemore, JD

Facts

In 1979 Irving Bussing (plaintiff) purchased a 22.2 percent interest in an IBM 3031 Processor Complex (the computer) for approximately $245,000. Bussing paid $10,000 in cash up front and approximately $32,000 through short-term promissory notes paid off in 1980 and 1981, and he financed the rest of the purchase through a long-term promissory note. Bussing leased the computer to AG, which paid Bussing a yearly rent and gave Bussing 22.2 percent of sublease rents it received. Because Bussing and AG shared the profits related to the subleases, Bussing and AG were in a partnership for tax purposes.

Rule of Law

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Issue

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Holding and Reasoning (Williams. J.)

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