In the case of Commissioner of Internal Revenue v. Jesse C. Bollinger et al., 1987, the U.S Supreme Court ruled on a tax dispute involving a partnership that had leased property to its partners for use in their separate businesses. The IRS argued that this arrangement was not a legitimate business operation and therefore did not qualify for investment tax credits or deductions for depreciation under federal law. However, the court disagreed with the IRS's interpretation and held that such arrangements could indeed be considered valid partnerships under federal income tax laws if they were conducted as bona fide business operations rather than mere financial investments or attempts to avoid taxes. Therefore, these types of partnerships are entitled to claim investment tax credits and other deductions related to their properties.

In the dissenting opinion for Commissioner of Internal Revenue v. Jesse C. Bollinger et al., Justice Blackmun disagreed with the majority's interpretation of Section 337(a) of the Internal Revenue Code, arguing that it was not intended to apply to liquidations involving a single asset corporation like in this case. He believed that Congress had designed Section 337(a) as a relief provision for corporations undergoing complete liquidation and selling multiple assets over time, rather than those simply transferring one asset from corporate solution into individual ownership without recognizing gain or loss at the corporate level. Furthermore, he argued that applying Section 337(a) in such cases would create opportunities for tax avoidance schemes which were contrary to Congressional intent when drafting these provisions.