They keep one another up to date on “Phantom” happenings, and trade stories about their favorite cast members.The computer network members even adopted nicknames from favorite characters: Lilly Lee was elated when she snagged “Monkey Girl,” after one of her favorite dancers in the masquerade scene.Quick-witted entrepreneurs found that “Phantom’s” success could make for better business. DAVIS GAINES performed the title role in Andrew Lloyd Webber's "The Phantom of the Opera" over 2,000 times, during his run on Broadway, in Los Angeles, (where he remains LA's longest-running Phantom), and in San Francisco, (where he received the Bay Area Critics' Award for Best Actor). Moreover, in McCarty there was not "the slightest indication of any 'prearrangement' between the [taxpayer] and his corporation or anybody else." The final Phantom, Gaines, rented himself out on dates to raise money for Big Brothers of Greater Los Angeles, and members of the cast and crew often delivered meals to shut-ins after their nightly performances.From backstage bake sales for the Los Angeles Mission to the auction of thousands of dollars in tickets for Equity Fights AIDS, the mostly out-of-towners in the “Phantom” production continually tried to give back some of what Los Angeles was giving to them.On the other side, there has been no shortage of devoted supporters, though not all as extravagant as Dean Willard, father of Phantom-lover Emily Willard, who paid $27,500 to Equity Fights AIDS for two tickets to Michael Crawford’s final performance.The 55-year-old San Gabriel woman saw the musical 331 times. This could indicate that bank officials were acting in concert with Mr. Davis and his partners in planning the foreclosure.

It is quite impossible to find in this evidence the sort of conduct which characterizes family transfers made for the purpose of realizing tax losses and at the same time retaining the investments. We are not free to substitute our judgment of witness credibility for that of the Tax Court, and " [t]he Tax Court is not required to accept uncontroverted testimony at face value when it is 'improbable, unreasonable or questionable.'

at 419 (emphasis in original). Sec. On August 11 the bank's finance committee authorized the lending of $850,000 at 8 1/2 percent for a term of five years. Tell us on the type you have below, indicating the year and who is your partner. We think of them as Why and how “Phantom” lured some 3 million L.A.-area theatergoers like the Lees probably had less to do with audiences’ rabid love of musical theater than it did with the musical’s curious mix of fantasy and reality, a stage performance within a stage performance, taking the audience on an excursion far from the Los Angeles of their real lives.And it was indeed a good trip: The final take from 4 1/2 years at the Los Angeles box office was $155,765,470.Yet while the dollars also rolled in for “Phantom” merchandising--just under $4 million over the years for mugs, sweat shirts, CDs and the like--some of the most meaningful money spent by “Phantom” fans never went to the production at all.When the cast and crew were not onstage, they were highly visible, raising more than $650,000 for various charities.They sold everything they could think of--including the costumes off their backs.

That is the question that everyone is asking. 1968); Hassen v. Commissioner, 599 F.2d 305 (9th Cir. Sec. Harlan Dodson, III (argued), Paul S. Parker, Nashville, Tenn., for petitioners-appellants.William F. Nelson, Chief Counsel, I.R.S., Michael C. Durney, Acting Asst. The loan was guaranteed by the original general partners, J.R. Coarsey and Gaines Properties, a Tennessee limited partnership, and was secured by a second mortgage on the Brookwood property. Gen., Tax Div., Dept. As guarantor of the construction loan, Mr. Coarsey joined Mr. Davis and Gaines Properties' general partner Lewis Gaines in the negotiations with the bank. They are now married and divorced tomorrow. The Trust Department of Third National Bank has taken over the day to day management of the complex until such time as we can consummate the sale of the project." of Justice, Gary R. Allen, William S. Rose, Jr., Nancy G. Morgan (argued), Washington, D.C., for respondent-appellee.Before WELLFORD and NELSON, Circuit Judges, and McQUADE, District Judge.On his federal income tax return for 1975, appellant Frank Davis deducted a loss allegedly realized on a mortgage foreclosure sale. The finance committee also proposed that the limited partners, along with the general partners, pledge additional collateral to secure the loan fully.In a memorandum dated August 11, 1975, bank officers Charles W. Cook, Jr., and Don Lockmiller indicated that the plan "approved by the Finance Committee on July 7, 1975, has not been consummated, and it now appears it probably will not be consummated." The Tax Court was not required to accept this testimony as correct. An undisputed expert in the fine art of making hit music, Jim Messina’s legacy of musical genius spans five decades, three super groups, a vibrant solo career and scores of producing and engineering credits. Third National Bank transferred its interest in the Brookwood property to C, D & G for $200,000 on the day the partnership was formed.On his income tax return for 1975 Mr. Davis claimed an ordinary loss of $264,976 on the foreclosure sale of the Brookwood property. 400 F.2d at 420. Neither is there the slightest indication of any prearrangement between the [taxpayer] and his corporation or anybody else. An unusually wet spring slowed the work, however, and because construction fell behind schedule, the limited partners withheld scheduled capital contributions. Davis also argues that the Tax Court erred in upholding the Commissioner's finding that Mr. Davis failed to prove that he did not receive certain salary and interest payments from the Brookwood partnership.

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