Legal Opinion

Terry J. & Chrisse J. Welle v. Commissioner

United States Tax Court

Decided June 27, 2013No. 156-11Published

1Opinion of the Court

140 T.C. No. 19

UNITED STATES TAX COURT TERRY J. WELLE AND CHRISSE J. WELLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 156-11. Filed June 27, 2013. P-H is the sole shareholder of TWC, a subch. C corporation. Ps used TWC to facilitate the construction of their lakefront home in that TWC kept track of construction costs and TWC’s framing crew framed the home. Ps, however, personally hired the subcontractors and ordered building supplies from the vendors in TWC’s name. Ps reimbursed TWC for its costs, including overhead, but did not pay TWC an amount equal to the…

2Cases cited37 opinions

  1. Palmer v. CommissionerSupreme Court of the United States · 1937
  2. Truesdell v. Comm'rUnited States Tax Court · 1987
  3. Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
  4. Commissioner v. WheelerSupreme Court of the United States · 1945
  5. Knudsen v. Comm'rUnited States Tax Court · 2008

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