Krukowski v. Commissioner
United States Tax Court
P was the sole shareholder of two C corporations. One corporation operated a health club; the other operated a law firm for which P worked as an attorney. P realized a loss renting a building to the health club, and he realized income renting a building to the law firm. P's 1994 Federal income tax return reported that the loss and income were both "passive" under sec. 469, I.R.C., and that the loss offset part of the income.
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P was the sole shareholder of two C corporations. One corporation operated a health club; the other operated a law firm for which P worked as an attorney. P realized a loss renting a building to the health club, and he realized income renting a building to the law firm. P's 1994 Federal income tax return reported that the loss and income were both "passive" under sec. 469, I.R.C., and that the loss offset part of the income. R disallowed the offset because, R determined, the recharacterization rule of sec. 1.469-2(f)(6), Income Tax Regs., deemed the income nonpassive. HELD: The…
1Opinion of the Court
THOMAS P. AND ERMINA A. KRUKOWSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Krukowski v. Commissioner
No. 7765-98
United States Tax Court
114 T.C. 366; 2000 U.S. Tax Ct. LEXIS 31; 114 T.C. No. 25;
May 22, 2000, Filed
An appropriate order will be issued, and decision will be entered for respondent.
P was the sole shareholder of two C corporations. One
corporation operated a health club; the other operated a law
firm for which P worked as an attorney. P realized a loss
renting a building to the health club, and he realized income
renting a building to the law firm. P's 1994 Federal…
2Cases cited29 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States National Bank v. Independent Insurance Agents of America, Inc.Supreme Court of the United States · 1993
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
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