¶1dissenting: I wish to record my dissent with respect to the “At Risk Issue.” I can find no meaningful difference between the facts in this case and those in Pritchett v. Commissioner, 85 T.C. 580 (1985). I would reach the same result as we did in that Court-reviewed opinion.
86 T.C. 360
Abramson v. Commissioner
Decided March 12, 1986
United States Tax Court · decided 1986-03-12
Held, partnership's purchase and distribution of film was an activity engaged in for profit where the purchase price was determined through arm's-length negotiations and distribution efforts resulted… Held: partnership's purchase and distribution of film was an activity engaged in for profit where the purchase price was determined through arm's-length negotiations and distribution efforts resulted in the expenditure of substantial sums of money.
Relies on Pritchett v. Commissioner
Good law ✅— No negative treatment on recordhow we know
Decided 1986-03-12
How this case has been cited
Cited by 200 later decisions — most recently February 2013 · most notably Antonides v. Commissioner (1988), Rose v. Commissioner (1987)
3 federal appellate · 1 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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