Pritchett v. Commissioner

827 F.2d 644 (1987)

Study Aids
Case Briefs Overview
Casebooks
Case Briefs
P
From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Pritchett v. Commissioner

United States Court of Appeals for the Ninth Circuit
827 F.2d 644 (1987)

Facts

Jerry Pritchett, Patricia Pritchett, and other taxpayers (taxpayers) (plaintiff) were members in five limited partnerships conducting oil and gas operations. The partnerships each had an agreement with Fairfield Drilling Corporation (Fairfield) in which Fairfield would provide operations in exchange for cash and a recourse note secured by the partnership assets. Only the general partners were personally liable; however, the general partners could enforce personal liability on the limited partners in the event of a deficiency. The partnerships allocated their accrued losses among the limited partners in proportion to their capital contributions. The limited partners took deductions on their taxes. The commissioner for the Internal Revenue Service (defendant) disallowed the deduction based on the recourse note, contending that the amount was not at risk and that the deduction was barred by § 465 of the Internal Revenue Code. The commissioner further argued that, under § 465(b)(3), the deductions were not allowed because Fairfield had a financial interest in the activity. The taxpayers appealed to the United States Tax Court, which affirmed the commissioner. The taxpayers appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (Skopil, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 812,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 812,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 812,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership

Casebooks

Federal Income Tax

Key Terms