Rousku v. Commissioner
United States Tax Court
Petitioner, as sole proprietor, operated an automobile body repair business during 1967, when he was a bona fide resident of Canada. For use in his business, he rented and later purchased garage space; owned necessary machinery, including air compressors, welding equipment, grinders, sanders, and paint-spraying equipment; and carried an inventory of fenders, bumpers, and other parts.
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Petitioner, as sole proprietor, operated an automobile body repair business during 1967, when he was a bona fide resident of Canada. For use in his business, he rented and later purchased garage space; owned necessary machinery, including air compressors, welding equipment, grinders, sanders, and paint-spraying equipment; and carried an inventory of fenders, bumpers, and other parts. Held, petitioner was engaged in a business in which capital was a material income-producing factor and is subject to the 30-percent limitation on the exclusion from gross income prescribed by sec. 911(b), I.R.C.…
1Opinion of the Court
George Rousku and Esther Rousku, Petitioners v. Commissioner of Internal Revenue, Respondent
Rousku v. Commissioner
Docket No. 2946-70
United States Tax Court
56 T.C. 548; 1971 U.S. Tax Ct. LEXIS 114;
June 21, 1971, Filed
Decision will be entered under Rule 50.
Petitioner, as sole proprietor, operated an automobile body repair business during 1967, when he was a bona fide resident of Canada. For use in his business, he rented and later purchased garage space; owned necessary machinery, including air compressors, welding equipment, grinders, sanders, and paint-spraying equipment; and carried an…
2Cases cited10 opinions
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Rousku v. CommissionerUnited States Tax Court · 1971
- Fairfax Mut. Wood Products Co. v. CommissionerUnited States Tax Court · 1945
- Miller v. CommissionerUnited States Tax Court · 1969
- Edward P. Allison Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1933
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