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CALLAHAN v. COMMISSIONER

Docket Nos. 48374-86, 1380-87, 1390-87, 1471-87, 1855-87, 1904-87, 1927-87, 4227-87, 4598-87, 4607-87, 4736-87, 5116-87.

98 T.C. 276 (1992)

JOHN E. AND ELLEN G. CALLAHAN, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 18, 1992.

Attorney(s) appearing for the Case

J. David Sanner, for petitioner.

James R. McCann, for respondent.

OPINION

GERBER, Judge:

This case is before the Court on the parties' cross-motions for partial summary judgment pursuant to Rule 1212 on the issue of whether petitioners, as limited partners, were at risk within the meaning of section 465 for amounts in excess of their actual cash contributions to the partnership for tax years 1980, 1981, and 1982.

Respondent determined deficiencies in income tax against petitioners...

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