United States Tax Court March 18, 1992, 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 (Callahan v. Commissioner)

lead-opinion

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.