Legal Opinion

Krukowski v. Commissioner

United States Tax Court

Decided May 22, 2000No. 7765-98Published

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

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  3. United States National Bank v. Independent Insurance Agents of America, Inc.Supreme Court of the United States · 1993
  4. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  5. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957

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