Legal Opinion
St. Charles Investment Co., Burton C. Boothby, Tax Matters Person v. Commissioner
United States Tax Court
Decided February 5, 1998No. 5793-96Unknown
1Opinion of the Court
110 T.C. No. 6
UNITED STATES TAX COURT ST. CHARLES INVESTMENT CO., BURTON C. BOOTHBY, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5793-96. Filed February 5, 1998. Prior to Jan. 1, 1991, X was a closely held C corporation, which incurred passive activity losses (PAL's) giving rise to suspended PAL's pursuant to sec. 469, I.R.C. A portion of the suspended PAL's was attributable to depreciation. X reduced the bases of the properties used in the passive activities by the amounts of such depreciation. X elected S corporation status as of Jan. 1, 1991.…
2Cases cited14 opinions
- Vimar Seguros Y Reaseguros, S. A. v. M/V Sky ReeferSupreme Court of the United States · 1995
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Lenz v. CommissionerUnited States Tax Court · 1993
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