Legal Opinion

Culnen v. Commissioner

United States Tax Court

Decided April 13, 2000No. 25551-92; No. 6496-94UnpublishedCited by 2 opinions

The issues for decision are: (1) whether P had sufficient basis with respect to an S corporation to permit him to deduct his pro rata share of that corporation's ordinary losses for the years in question; and (2) whether (A) the corporation suffered a sec. 1231, I.R.C., loss from the disposition of property in one of those years and (B) P had sufficient basis to permit him to deduct his pro rata share of that loss. 1. HELD: P established that he had sufficient basis for all…

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The issues for decision are: (1) whether P had sufficient basis with respect to an S corporation to permit him to deduct his pro rata share of that corporation's ordinary losses for the years in question; and (2) whether (A) the corporation suffered a sec. 1231, I.R.C., loss from the disposition of property in one of those years and (B) P had sufficient basis to permit him to deduct his pro rata share of that loss. 1. HELD: P established that he had sufficient basis for all years; 2. HELD, FURTHER, P established that the S corporation suffered only a portion of the sec. 1231, I.R.C., loss…

1Opinion of the Court

DANIEL J. CULNEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Culnen v. Commissioner

No. 25551-92; No. 6496-94

United States Tax Court

T.C. Memo 2000-139; 2000 Tax Ct. Memo LEXIS 169; 79 T.C.M. (CCH) 1933;

April 13, 2000, Filed

Decisions will be entered under Rule 155.

The issues for decision are: (1) whether P had sufficient

basis with respect to an S corporation to permit him to deduct

his pro rata share of that corporation's ordinary losses for the

years in question; and (2) whether (A) the corporation suffered

a sec. 1231, I.R.C., loss from the disposition of property in

one of those…

2Cases cited6 opinions

  1. Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
  2. Underwood v. CommissionerUnited States Tax Court · 1975
  3. Hitchins v. CommissionerUnited States Tax Court · 1994
  4. Prashker v. CommissionerUnited States Tax Court · 1972
  5. Bolding v. CommissionerCourt of Appeals for the Fifth Circuit · 1997

1 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Broz v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
  2. Homero F. Meruelo v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019

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