Marinos v. Commissioner
United States Tax Court
T.C. Memo 1989-492 (1989)
- Written by Sarah Holley, JD
Facts
Elia Marinos (plaintiff) and Robert Brodie entered into an agreement pursuant to which the parties agreed to lease a master audio record from Entertainment Marketing Co., Inc. Marinos promised to front the lease costs and to contract with Signal Records, Ltd., for the production and distribution of the record. The agreement stated that Marinos and Brodie were to each contribute one half to the venture and split income from the venture 50-50 as tenants in common. The agreement also stated that the arrangement was not in any way to be considered a partnership. The Internal Revenue Service (IRS) assessed additional taxes against Marinos. The assessment turned on whether Marinos and Brodie were partners, as the IRS claimed, or merely co-owners of property, as Marinos claimed.
Rule of Law
Issue
Holding and Reasoning (Drennen, J.)
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