Culnen v. Commissioner
United States Tax Court
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
- Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Underwood v. CommissionerUnited States Tax Court · 1975
- Hitchins v. CommissionerUnited States Tax Court · 1994
- Prashker v. CommissionerUnited States Tax Court · 1972
- Bolding v. CommissionerCourt of Appeals for the Fifth Circuit · 1997
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Broz v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- Homero F. Meruelo v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019