International Artists, Ltd. v. Commissioner
United States Tax Court
Held, an allocable portion of depreciation and maintenance expenses with respect to property owned by the corporate petitioner is deductible by the corporation. Such property was acquired and used for both personal and business purposes. Allocation determined.
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Held, an allocable portion of depreciation and maintenance expenses with respect to property owned by the corporate petitioner is deductible by the corporation. Such property was acquired and used for both personal and business purposes. Allocation determined. Held, further, the individual petitioner, president and dominant shareholder of the corporation, is chargeable with income as a result of his personal use of corporate property to the extent of an allocable portion of the fair rental value of the corporate property.
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in petitioners’ income taxes as follows:
International Artists, Ltd., docket No. 1569-68-TYE May Si— Deficiency 1963 $17, 652. 88 1964 26, 264. 23 1965 22, 429. 71
Walter V. Liberace, docket No. 1570-68-TYE Dec. 81— [ 1962 1963 1964 12, 937. 75 24, 233. 20 23, 483. 50
'The issues presented for decision are: (1) Whether the corporate petitioner is entitled to a deduction for depreciation and operating-expenses with respect to realty owned by the corporate petitioner and used in part by its controlling shareholder as a personal residence; and, if so,…
2Cases cited13 opinions
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Heuer v. CommissionerUnited States Tax Court · 1959
- Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- Greenspon v. CommissionerUnited States Tax Court · 1954
8 more not listed; retrieve them via the Exa API.
3Cited by103 opinions
- Nicholls, North, Buse Co. v. CommissionerUnited States Tax Court · 1971
- Browne v. CommissionerUnited States Tax Court · 1980
- Charles W. Ireland and Carolyn P. Ireland v. United StatesCourt of Appeals for the Fifth Circuit · 1980
- Gino v. CommissionerUnited States Tax Court · 1973
- Greenspun v. CommissionerUnited States Tax Court · 1979
98 more not listed; retrieve them via the Exa API.